IR 05000327/2018001
| ML18127A050 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/07/2018 |
| From: | Masters A NRC/RGN-II/DRP/RPB5 |
| To: | James Shea Tennessee Valley Authority |
| References | |
| IR 2018001 | |
| Download: ML18127A050 (20) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION May 7, 2018
SUBJECT:
SEQUOYAH NUCLEAR PLANT - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000327/2018001 AND 05000328/2018001
Dear Mr. Shea:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Sequoyah Nuclear Plant Units 1 and 2. On April 5, 2018, the NRC inspectors discussed the results of this inspection with Mr. Dennis Dimopoulos and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented two self-revealing findings of very low safety significance in this report. These findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as an NCV consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, 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 the Sequoyah Nuclear Plant.
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 the Sequoyah Nuclear Plant.
J.Shea 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/
Anthony D. Masters, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 05000327, 05000328 License Nos.: DPR-77, DPR-79
Enclosure:
IR 05000327/2018001 and 05000328/2018001
Inspection Report
Docket Number(s): 50-327, 50-328 License Number(s): DPR-77, DPR-79 Report Number(s): 05000327/2018001 and 05000328/2018001 Enterprise Identifier: 1-2018-001-0063 Licensee: Tennessee Valley Authority (TVA)
Facility: Sequoyah Nuclear Plant Location: Soddy-Daisy, TN 37379 Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors: D. Hardage, Senior Resident Inspector G. Eatmon, Resident Inspector W. Deschaine, Resident Inspector Approved By: A. Masters, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a quarterly integrated inspection at Sequoyah Nuclear Plant, 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. NRC and self-revealed findings, violations, and additional items are summarized in the table below. Licensee-identified non-cited violations (NCVs) are documented in report sections: 71153.
List of Findings and Violations Essential Raw Cooling Water Pumps Inoperable due to Frozen Motor Bearing Cooling Lines Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green None 71111.15 -
Systems NCV Operability 05000327, 328/2018001-01 Determinations Closed and Functionality Assessments A self-revealing Green NCV of Technical Specification 5.4.1, Procedures, was identified when Sequoyah/TVA did not establish, implement and maintain applicable procedures recommended in Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance. Specifically, the essential raw cooling water (ERCW) pump motor maintenance procedure, 0-MI-MRR-067-002.0, Removal/Disassembly/Reassembly Instruction for ERCW Pumps does not contain specific direction for the slope of the motor bearing cooling supply and return lines for the motor reassembly.
Improper Calibration of Reactor Trip Instrumentation Results in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.9 - Training 71153 -
Systems NCV Licensee 05000327/2018001-02 Event Closed Reports A self-revealing Green finding and associated NCV of Sequoyah Unit 1 Technical Specification 5.4, Procedures, was identified on June 25, 2016, when the licensee did not implement procedures to calibrate Delta-T/Tavg Channel IV with the correct test equipment input impedance settings, which resulted in Delta-T/Tavg Channel IV being out of technical specifications allowed tolerances.
Additional Tracking Items Type Issue number Title Report Status Section Licensee 05000327/2016-006-00 Improper Calibration of 71153 Closed Event Reactor Trip Report Instrumentation Results in (LER) Condition Prohibited by Technical Specifications Type Issue number Title Report Status Section LER 05000327/2016-009-00 Manual Reactor Trip During 71153 Closed Startup Due to a Control Rod Misalignment Type Issue number Title Report Status Section LER 05000327,05000328/ Breached Door Renders Both 71153 Closed 2017-001-00 Trains of the Auxiliary Building Gas Treatment System Inoperable Type Issue number Title Report Status Section LER 05000327, 05000328/ Automatic Actuation of 71153 Closed 2017-002-00 Emergency Diesel Generators Due to Loss of Power to 6.9kV Shutdown Board
PLANT STATUS
Unit 1 began the inspection period at 100 percent rated thermal power (RTP). On February 5, 2018, operators reduced power to 25 percent RTP to remove the main turbine from service to perform maintenance on the turbines electrohydraulic control system. The unit returned to 100 percent RTP on February 7, 2018, and remained there for the rest of the inspection period.
Unit 2 operated at or near 100 percent 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 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
71111.04 - Equipment Alignment Partial Walkdown
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 and 2 ERCW, on January 23, 2018
- (2) Unit 2 emergency diesel generator A starting air, on February 13, 2018
- (3) Unit 2 component cooling water system A while component cooling water pump B was out of service, on February 15, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of:
- (1) Unit 1 and Unit 2 component cooling system, on March 26, 2018
71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 2, auxiliary building - El. 669, on January 25, 2018
- (2) Unit 1 and Unit 2, control building - El. 706, on January 25, 2018
- (3) Unit 1 and Unit 2 , auxiliary building - El. 759, on February 15, 2018
- (4) Unit 1 and Unit 2, auxiliary building - El. 714, on March 7, 2018
- (5) Unit 1 and Unit 2, auxiliary building- El. 690, on March 26, 2018
71111.06 - Flood Protection Measures Cables
The inspectors evaluated cable submergence protection in:
- (1) HH82 on February 21, 2018
- (2) MH32A1, MH33, MH14A, MH24, and MH25 on February 21, 2018
71111.07 - Heat Sink Performance Heat Sink
The inspectors observed the licensees component cooling water (CCS) 1A2 heat exchanger inspection and the state of cleanliness of the heat exchanger plates on March 6, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification
The inspectors observed and evaluated, Identification and Immediate Actions for a Faulted Steam Generator Isolation and Steam Generator Tube Rupture on February 27, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated licensed operator performance in the main control room during the unplanned Unit 1 downpower to 25 percent RTP on February 5, 2018, in response to turbine control anomalies.
71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Review of Sequoyahs thirteenth 10 CFR 50.65 (a)(3) periodic evaluation on March 16, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 1 and Unit 2, week of January 14 - January 20, 2018, including protected equipment status reviews for scheduled maintenance on the L-B ERCW pump and the emergent inoperablity of P-B and M-B ERCW pumps due to loss of motor cooling water flow
- (2) Unit 1 elevated risk due to emergent main turbine controls malfunction and downpower to 25 percent RTP to remove the turbine from service and perform corrective maintenance, on February 5-7, 2018
- (3) Unit 1 and Unit 2, week of March 4 - March 10, 2018, including protected equipment status reviews for scheduled maintenance on the 1A component cooling system heat exchanger and the emergent removal from service of the A common station service transformer
- (4) Unit 1 and Unit 2, week of March 19 - March 23, 2018, including protected equipment status reviews for scheduled maintenance on the 2A safety injection pump
71111.15 - Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 1 and 2, ERCW pump motor cooling lines susceptible to freezing, Condition Report (CR)1380675, on January 29, 2018
- (2) Unit 1 and 2, B-B ERCW SWP failed Section XI acceptance criteria, CR1379440, on February 1, 2018
- (3) Unit 1, SIS pump discharge to RWST valve nuts have less than full thread engagement, CR 1384800, on February 26, 2018
- (4) Unit 1, reactor trip breaker A abnormal light indications, CR1383922 on, March 21, 2018
- (5) Unit 1 and 2, Incorrect sized breaker installed in plant, CR1388832, on March 28, 2018
71111.18 - Plant Modifications
The inspectors evaluated the following temporary or permanent modifications:
- (1) SQN-1-2017-062-002, Crimp and Furminite CVCS drain line, on February 14, 2018
71111.19 - Post Maintenance Testing
The inspectors evaluated the following post maintenance tests:
- (1) Work Order (WO) 118594012, 6.9kv shutdown board loss of voltage, overvoltage and degraded voltage relay calibration, on January 22, 2018
- (2) WO 119368856, Remove A train SSPS from service to allow troubleshooting of blown fuse for A reactor trip breaker shunt coil, on February 4, 2018
- (3) WO 119229100, Install TMOD SQN-1-2017-062-002 to reduce unidentified RCS leakage, on February 12, 2018
- (4) WO 119191043, 1A component cooling system heat exchanger cleaning, on March 9, 2018
- (5) WO 118828740, Belt inspection, fan bearing lube and clean of Spent Fuel Pool and Thermal Barrier Booster Pump cooler B-B, on March 30, 2018
71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine
- (1) 1-SI-OPS-082-007.A, Electrical Power System Diesel Generator 1A-A, on February 26, 2018
In-service (2 Samples)
- (1) 1-SI-SXP-063-201.A, Safety Injection Pump 1A-A Performance Test, on February 7, 2018
- (2) 2-SI-SXP-074-201.B, Residual Heat Removal Pump 2B-B Performance Test, on March 5, 2018
Reactor Coolant System Leak Detection (1 Sample)
- (1) 0-SI-OPS-068-137.0, Unit 1 Reactor Coolant System Water Inventory, on March 22, 2018
71114.06 - Drill Evaluation Emergency Planning Drill
- (1) The inspectors evaluated the emergency preparedness drill on January 31, 2018. The drill included:
- loss of the annunciator system
- a main feedwater pump tripping
- loss of offsite power with both emergency diesel generators not being available
- (2) The inspectors evaluated the emergency preparedness drill on March 7, 2018. The drill included:
- a reactor coolant system (RCS) unidentified leak of 33 gpm occurred
- an earthquake then happened damaging the 1B 6.9 KV Shutdown Board, unisolable Main Steam line breaks on Steam Generators 1 and 4 occurred, a large rupture to the RWST, and a small break LOCA.
- the small break LOCA enlarged to a full shear of the #1 Cold Leg and both RHR pumps seized due to the shaking caused by the earthquake
- the use of the Severe Accident Management Guidelines (SAMG)
OTHER ACTIVITIES - BASELINE
71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Reactor Trip Breaker A (RTA) abnormal light indications from a fuse failure, CR
1383922, on March 30, 2018 71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) LER 05000327/2016-006-00, Improper Calibration of Reactor Trip Instrumentation Results in Condition Prohibited by Technical Specifications on September 12, 2016
- (2) LER 05000327/2016-009-00, Manual Reactor Trip During Startup Due to a Control Rod Misalignment, on February 27, 2017
- (3) LER 05000327,05000328/2017-001-00, Breached Door Renders Both Trains of the Auxiliary Building Gas Treatment System Inoperable, on April, 26, 2017
- (4) LER 05000327, 05000328/2017-002-00, Automatic Actuation of Emergency Diesel Generators Due to Loss of Power to 6.9kV Shutdown Board, on June 25, 2016
Personnel Performance (1 Sample)
The inspectors evaluated the loss of B train ERCW to both units and licensees performance on January
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL International Atomic Energy Agency (IAEA) Operational Safety Review Team (OSART)
Assessment - August 14 - August 31, 2017 The International Atomic Energy Agency is an independent intergovernmental, science and technology-based organization, in the United Nations family, that serves as the global focal point for nuclear cooperation. One of the services provided is an independent assessment of licensee performance by senior staff members from the IAEA member states. This assessment team is called an Operational Safety Review Team, or OSART. The focus of the review by the OSART is on the safety and reliability of plant operation through review of the operation of the plant and the performance of TVAs management and staff. The NRC believes that it would be beneficial for the U.S. Nuclear power industry to continue to volunteer and participate in the OSART missions. To help ensure that U.S. licensees participate in the operational safety assessment review team missions, the NRC has decided to and will grant a one-time regulatory inspection credit (a reduction in the baseline program) for those baseline programs that overlap with the OSART review as directed and outlined in Manual Chapter 2515, Section 08.05, Baseline Inspection Credit for Operational Safety Review Team Effort, dated March 28, 2017.
Between August 14 and August 31, 2017, TVA personnel debriefed the inspectors about issues identified by the OSART assessment team on a daily basis. The inspectors also participated in weekly OSART team leader debriefs and the OSART team exit on August 31, 2017. The inspectors used the information provided during the daily and weekly debriefs and the final OSART exit meeting to screen the issues identified by OSART for immediate safety concerns.
None were identified.
NRC inspectors reviewed both a draft and final version of the OSART report. Inspectors screened the issues documented in the reports to identify issues that required additional NRC review in accordance with the reactor oversight process. Issues identified as requiring additional NRC follow-up will be reviewed by inspectors during routine baseline inspection activities. Findings identified will be documented in applicable NRC inspection reports.
Based on the results of the inspectors review and assessment of the scope of OSART activities through the debriefs and the review of the draft and final OSART mission report, NRC Region II management approved for Sequoyah regulatory inspection credit in the baseline inspection procedures described in Section 08.05 of Inspection Manual Chapter (MC) 2515. Based on the summary of radiation safety-related inspection activities documented in the OSART draft and final report and radiation protection activities observed during the OSART inspection, radiation safety inspection activities for Sequoyah will be credited 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />. The inspectors determined that due to the timing of the issuance of the final OSART mission report, providing credit for emergency preparedness inspections that will not be performed until September 2019, did not meet the intent of the credit guidelines established in IMC 2515; therefore the hours credited to emergency preparedness inspection activities for Sequoyah will be zero. Inspection areas contained within the NRC inspection procedures (IP 71111.22 and IP 71111.05AQ) are not documented in the report therefore hours credited to Surveillance Testing and Fire Protection inspection activities for Sequoyah will be zero. Full regulatory inspection credit for the IP 71152B, Problem Identification & Resolution as described in IMC 2515 of 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> will be credited based on the OSART. The NRC has made the final OSART report publicly available on the NRC website, Agency Documents Access and Management System (ADAMS) accession number ML18061A036.
INSPECTION RESULTS
Observation
71152 - Annual
Follow-up of Selected Items Annual Follow-up of Selected Issues: Reactor Trip Breaker abnormal light indications caused by a fuse failure The inspectors conducted a detail review of CR 1383922, Reactor Trip Breaker A (RTA)abnormal light indications from a fuse failure. The inspectors chose this sample due to a number of issues the site has had regarding Bussmann KWN and KTN type fuses dating back to 2011 and a 2005 Part 21 report on these type fuses from Bussmann. For CR 1383922, the licensee determined that inadequate heating during the manufacturing process caused a poor solder connection, thus causing the fuse to open up inadvertently. The failure caused by a manufacturing defect was previously identified by review of the 2005 Part 21 report and by a Root Cause performed in 2011. The inspectors reviewed the licensees corrective actions to evaluate the population of Bussmann fuses installed in the plant and risk rank replacement of these fuses with a different kind. The inspectors determined that the licensees plan to address this issue was reasonable commensurate with the safety significance of equipment that might be affected by these type of fuses.
Licensee Identified Non-Cited Violation 71153 -
Licensee Event Reports This violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Sequoyah Unit 1 and Unit 2 Technical Specification 3.7.12, Auxiliary Building Gas Treatment System (ABGTS), requires two ABGTS trains be operable in modes 1, 2, 3, and 4.
Contrary to the above, from March 3-7, 2017, the licensee blocked open door A212 resulting in the inoperability of the auxiliary building secondary containment enclosure boundary and thus inoperability of both trains of the ABGTS.
Significance/Severity Level: Green. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding was of very low safety significance (Green)because the finding only represents a degradation of the radiological barrier function provided for the auxiliary building.
Corrective Action Reference: CR1269767 Essential Raw Cooling Water Pumps Inoperable due to Frozen Motor Bearing Cooling Lines Cornerstone Significance Cross-cutting Report Section Aspect Mitigating System Green None
71111.15 - NCV Operability
05000327/328/2018001-01 Determinations Closed and Functionality Assessments A self-revealing Green NCV of Technical Specification 5.4.1, Procedures, was identified when Sequoyah/TVA did not establish, implement and maintain applicable procedures recommended in Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance. Specifically, the ERCW pump motor maintenance procedure, 0-MI-MRR-067-002.0, Removal/Disassembly/Reassembly Instruction for ERCW Pumps does not contain specific direction for the slope of the motor bearing cooling supply and return lines for the motor reassembly.
Description On January 18, 2018, at 0121, with ambient temperature below freezing, the licensee placed M-B ERCW Pump in service and removed L-B ERCW pump from service for maintenance. At 0342, operators started P-B ERCW pump and secured M-B ERCW pump due to increasing motor bearing temperatures on the M-B ERCW pump. P-B ERCW pump subsequently had increasing motor bearing temperatures. Operators started N-B ERCW pump and stopped P-B ERCW pump. At 0615, the B ERCW header was declared inoperable on both units due to the inoperability of L-B, M-B and P-B ERCW pumps.
ERCW pump motor bearing cooling is supplied from the pump discharge. The pump motor bearing cooling lines were originally heat traced to ensure water in the line would not freeze when a pump was not running and ambient temperatures were below freezing. ERCW motor bearing cooling was redesigned in 1989 to remove heat tracing and to slope the motor cooling lines such that the motor cooling water lines would self-drain, and thus be free of water and not susceptible to freezing when the pump is not in service. However, licensee procedure, 0-MI-MMR-067-002.0, Removal/Disassembly/Reassembly Instruction for ERCW Pumps did not incorporate guidance to ensure the proper slope of the ERCW pump motor bearing cooling lines following maintenance such that the lines would self-drain. Inspection determined that five of the eight ERCW pumps J-A, K-A and pumps M-B, N-B and P-B all had improperly sloped motor cooling lines that allowed water to remain in the lines when the pumps were not running.
Corrective Actions: On January 18, licensee personnel mobilized temporary heat tracing and 480V space heaters to thaw the ERCW pump motor bearing cooling water lines. On January 18 at 1345, P-B ERCW pump was restored to operable status following a pump run and verification of acceptable motor bearing cooling flow and bearing temperatures. This restored B train ERCW to operable status. As an interim action, the licensee implemented Standing Order SO-18-003 to address the improper slopes for the motor cooling lines, and have operators declare the ERCW J-A, K-A, M-B, N-B, and P-B pumps inoperable when outside air temperatures are below freezing unless the pumps are in service. The licensee completed corrective maintenance to ensure proper slope on all ERCW pump motor cooling water piping on February 16, 2018.
Corrective Action Reference: : CR1380675, CR1378392, CR1378822, CR1378392
Performance Assessment:
Performance Deficiency: The licensees failure to ensure ERCW motor maintenance procedure, 0-MI-MRR-067-002.0, Removal/Disassembly/Reassembly Instruction for ERCW Pumps contained specific direction for the slope of the motor cooling supply and return lines for the motor reassembly was a performance deficiency.
Screening: The performance deficiency was associated with the maintenance procedure quality attribute of the mitigating system cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of the ERCW system to respond to an initiating event and prevent undesirable consequences. Specifically, the failure to ensure the ERCW motor maintenance procedure contained direction for the slope of the motor cooling supply and return lines resulted in the loss of motor cooling water flow that rendered standby ERCW pumps inoperable during ambient freezing conditions.
Significance: In accordance with Inspection Manual Chapter (IMC) 06 Initial Characterization of Findings, dated October 7, 2016, this finding affected the mitigating systems cornerstone because ERCW provides the ultimate heat sink which impacts core decay heat removal. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding was of very low safety significance (Green) because the finding
- (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2)did not represent a loss of system and/or function,
- (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and
- (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensees maintenance rule program.
Cross-cutting Aspect: The inspectors did not assign a cross-cutting aspect because the finding did not reflect present licensee performance because the failure to update this licensee maintenance procedure with design requirement from the design change occurred outside the three year window.
Enforcement:
Violation: Sequoyah Technical Specification 5.4.1, Procedures, requires, in part, that procedures be established, implemented and maintained for the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, dated February 1987. Regulatory Guide 1.33, Section 9.a, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly performed in accordance with written procedures appropriate to the circumstances.
Contrary to the above, from May 1989 until January 2018, the licensee did not maintain procedures for maintenance on ERCW pumps appropriate to the circumstance; specifically, procedures to reassemble ERCW pumps lacked instructions to ensure the correct slope for the motor bearing cooling lines was maintained.
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
NCV 5000327/2018001-01; Improper Calibration of Reactor Trip Instrumentation Results in a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.9 - Training 71153 -
Systems NCV Licensee 05000327/328/2018001-02 Event Closed Reports A self-revealing Green finding and associated NCV of Sequoyah Unit 1 Technical Specification 5.4, Procedures, was identified on June 25, 2016, when the licensee did not implement procedures to calibrate Delta-T/Tavg Channel IV with the correct test equipment input impedance settings, which resulted in Delta-T/Tavg Channel IV being out of technical specifications allowed tolerances.
Description:
On June 23, 2016, the digital filter processor card associated with Unit 1 Delta-T/Tavg channel IV failed and operators declared Delta-T/Tavg channel IV inoperable. The card was replaced on June 24, 2016, and a channel calibration was performed prior to returning the channel to operable status. The normal measuring and test equipment (MTE)used to perform this calibration was not available. Maintenance personnel instead used a Fluke 8845A. Use of the Fluke 8845A was allowed by the calibration procedure; however, this instrument has a different default input impedance setting than the MTE. Maintenance personnel performing the calibration were unaware of the default input impedance difference and the procedure did not identify and require the use of the correct internal impedance setting. As a result, licensee procedure 1-SI-IFT-068-067.4, Functional Test of T/TAVG Channel IV Rack 13 Loop 1-T-68-67 (T-441/442), was performed with the test instrumentation impedance setting not set correctly and resulted in Delta-T/Tavg Channel IV being adjusted incorrectly and out of technical specifications allowed tolerances. Operations personnel declared Delta-T/Tavg Channel IV operable on June 25 at 0215 based on the improper calibration. On June 27, 2016, licensee reactor engineers noted Tavg had taken a two-degree step change lower following the digital filter card replacement and the licensee began investigation and identified the incorrect input impedance was used during previous performance of the Delta-T/Tavg Channel IV calibration. On June 29 at 23:30, Delta-T/Tavg Channel IV was returned to operable status following calibration and functional testing using MTE with appropriately configured input impedance.
Corrective Actions: The licensee performed the calibration and functional testing of Delta-T/Tavg Channel IV with the correct input impedance to restore compliance on June 29, 2016.
The licensee has revised calibration procedures to ensure the correct impedance settings are used.
Corrective Action Reference: CR 1187308
Performance Assessment:
Performance Deficiency: The licensees failure to ensure the test equipment used to perform calibration of Delta-T/TAVG Channel IV was configured to the appropriate input impedance was a performance deficiency.
Screening: This performance deficiency was associated with the mitigating systems cornerstone and was more than minor because it adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, licensee personnel use of the Fluke 8845A with the incorrect input impedance setting resulted in the inoperability of reactor protection system input signals.
Significance: This performance deficiency was associated with the mitigating systems cornerstone. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012.
Because all three questions in Section C of Exhibit 2, Mitigating Systems Screening Questions, were answered no, the finding screened as Green.
Cross-cutting Aspect: The inspectors determined that the finding has a cross-cutting aspect of training in the human performance area because licensee personnel had not been trained on the use of the Fluke 8845A and were not aware of the difference in default input impedance settings. (H.9)
Enforcement:
Violation: Violation: Sequoyah Unit 1 Technical Specification 5.4.1 requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Appendix A, section 9.a requires, in part, that maintenance of safety-related equipment is performed in accordance with written procedures appropriate to the circumstances.
Contrary to the above, on June 25, 2016, the licensee did not implement procedures to calibrate Delta-T/Tavg Channel IV with the correct test equipment input impedance settings.
The licensee restored compliance on June 29, 2016 by performing the calibration and functional testing of Delta-T/Tavg Channel IV with the correct input impedance settings.
Disposition: 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 April 5, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. D. Dimopoulos, and other members of the licensee staff.
DOCUMENTS REVIEWED
Procedures
0-SO-67-1, Essential Raw Cooling Water, Revision 109
2-SO-70-1, Att.3, Component Cooling Water System A Train Valve Checklist 2-70-1.03,
December 31, 2012
0-SO-30-10 Att. 9, Auxiliary Building Ventilation Systems, Plant Operability Impacts
(Tech Spec/TRM) Associated with ESF Coolers, August 22, 2016
0-SO-82-7, Diesel Generator 2A-A Support Systems, Revision 25
Procedures
Sequoyah Fire Protection Report, Part II - Fire Protection Plan, Revision 36
PFP NO: AUX-0-669-00, Fire Protection Pre-Fire Plans Auxiliary Building - El. 669, Revision 4
PFP NO: AUX-0-669-02, Fire Protection Pre-Fire Plans Auxiliary Building - El. 669 (Unit 2
Side), Revision 10
PFP NO: AUX-0-669-03, Fire Protection Pre-Fire Plans Auxiliary Building - El. 669 (Unit 1
Side), Revision 7
B87 150915 003, SQN Combustible Loading Calculation for Room 669.0-A01, Revision 5
PFP NO: CON-0-706-00, Fire Protection Pre-Fire Plans Control Building - El. 706, Revision 7
MMTP-102, Erection of Scaffolds/Temporary Work Platforms and Ladders, Revision 14
SQN-DC-V-1.3.4, Category 1 Cable Tray Support Systems, August 20, 1975
B87 960829 003, Guidelines for the Erection of Scaffolding, Revision 2
PFP NO: AUX-0-749-00, Fire Protection Pre-Fire Plans Auxiliary Building - El. 749 & 759,
Revision 4
PFP NO: AUX-0-749-01, Fire Protection Pre-Fire Plans Auxiliary Building - El. 749 (Unit 1
Side), Revision 9
PFP NO: AUX-0-749-02, Fire Protection Pre-Fire Plans Auxiliary Building - El. 749 (Unit 2
Side), Revision 10
Condition Reports
1383239, Housekeep issue Unit 2 AB El 669
1343240, NRC observation of Pre-Fire Plans
1380273, NRC Identified: Ladder installed without appropriate evaluation/approval
Procedures
SQN-0-MNWY-317-HH3, PM#052053000, Attachment A
Work Orders
Procedures
0-TI-SXX-000-146.0, Program for Implementing NRC Generic Letter 89-13, Revision 4
0-MI-MRR-070-611.0, Component Cooling System Heat Exchanger Maintenance, Revision 12
Work Orders
E-0, Reactor Trip or Safety Injection, Revision 39
E-2, Faulted Steam Generator Isolation, Revision 16
E-3, Steam Generator Tube Rupture, Revision 23
CR1303568, Unit 2 Turbine and Rx Shutdown due to main turbine drain line steam break
Procedures
TI-4, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting -
10CFR50.65, Revision 30
Procedures
NPG-SPP-07.3, Work Activity Risk Management Process, Revision 22
NPG-SPP-07.2.4, Forced Outage or Short Duration Planned Outage Management, Revision 7
NPG-SPP-07.2, Outage Management, Revision 8
Procedures
NEDP-22, Operability Determinations and Functional Evaluations, Revision 18
OPDP-8, Operability Determination Processes and Limiting Conditions for Operation Tracking,
Revision 24
0-SI-SXP-067-202.B, ERCW Traveling Screen Wash Pump B-B Performance Test, Revision 13
Functionality Evaluation Documentation for CR 1265450 & 1379440, dated January 23, 2018
Condition Reports
1379440, B-B ERCW SWP failed Section XI acceptance criteria
1384033, perform extent of condition review for part 21 report
Work Orders
118629224
119368807
Procedures
NPG-SPP-09.3, Plant Modifications and Engineering Change Control, Revision 27
NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments, Revision 12
NPG-SPP-09.5, Temporary Modifications Temporary Configuration Changes, Revision 12
Procedures
NPG-SPP-06.3, Pre-/Post-Maintenance Testing, Revision 1
NPG-SPP-06.9, Testing Programs, Revision 1
NPG-SPP-06.9.1, Conduct of Testing, Revision 10
NPG-SPP-06.9.3, Post-Modification Testing, Revision 9
1-SI-OPS-202-253.A, Function Test of Loss of Voltage Relays On 6.9KV Shutdown Board 1A-A,
Revision 20
Work Orders
WO119341490
rocedures
NPG-SPP-06.9.1, Conduct of Testing, Revision 10
1-SI-SXP-063-201.A, Safety Injection Pump 1A-A Performance Test, Revision 21
1-SI-OPS-082-007.A, Electrical Power System Diesel Generator 1A-A, Revision 66
2-SI-SXP-074-201.B, Residual Heat Removal Pump 2B-B Performance Test, Revision 17
Work Orders
WO118691071
Procedures
EPIP-1, Emergency Plan Classification Matrix, Revision 52
EPIP-2, Notification of Unusual Event, Revision 35
EPIP-3, Alert, Revision 37
EPIP-4, Site Area Emergency, Revision 39
EPIP-5, General Emergency, Revision 48
Procedures
NPG-SPP-22.300, Corrective Action Program, Revision 10
NPG-SPP-22.303, CR Actions, Closures and Approvals, Revision 10
Operator Chronological Logs
AOP-C.01 Rod Control Malfunctions, Revision 26
0-MI-EBR-202-007.5, 6.9kV ABB Type 7.5 HK Breaker Inspection, Revision 0001
NPG-SPP-06.14 TROUBLESHOOTING PLAN
CR 1299591, Unit Board 28 Breaker 1814 Failed Open During Shutdown board 2A-A Transfer
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
May 7, 2018
Mr. Joseph W. Shea
Vice President, Nuclear Regulatory Affairs
and Support Services
Tennessee Valley Authority
1101 Market Street, LP 4A
Chattanooga, TN 37402-2801
SUBJECT: SEQUOYAH NUCLEAR PLANT - NUCLEAR REGULATORY COMMISSION
INTEGRATED INSPECTION REPORT 05000327/2018001 AND
Dear Mr. Shea:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Sequoyah Nuclear Plant Units 1 and 2. On April 5, 2018, the NRC inspectors discussed
the results of this inspection with Mr. Dennis Dimopoulos and other members of your staff. The
results of this inspection are documented in the enclosed report.
NRC inspectors documented two self-revealing findings of very low safety significance in this
report. These findings involved violations of NRC requirements. The NRC is treating these
violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement
Policy.
Further, inspectors documented a licensee-identified violation which was determined to be of
very low safety significance in this report. The NRC is treating this violation as an NCV
consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within
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 the Sequoyah Nuclear Plant.
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 the Sequoyah Nuclear Plant.
J.Shea
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/
Anthony
- D. Masters, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Docket Nos.: 05000327, 05000328
Enclosure:
IR 05000327/2018001 and 05000328/2018001
cc w/ encl: Distribution via ListServ
OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP
NAME SNinh GEatmon WDeschaine DHardage AMasters
DATE 4/25/2018 4/24/2018 4/24/2018 4/24/2018 5/7/2018
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number(s): 50-327, 50-328
License Number(s): DPR-77, DPR-79
Report Number(s): 05000327/2018001 and 05000328/2018001
Enterprise Identifier: 1-2018-001-0063
Licensee: Tennessee Valley Authority (TVA)
Facility: Sequoyah Nuclear Plant
Location: Soddy-Daisy, TN 37379
Inspection Dates: January 1, 2018 to March 31, 2018
Inspectors:
- D. Hardage, Senior Resident Inspector
- G. Eatmon, Resident Inspector
- W. Deschaine, Resident Inspector
Approved By:
- A. Masters, Chief
Reactor Projects Branch 5
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance
by conducting a quarterly integrated inspection at Sequoyah Nuclear Plant, 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. NRC and self-
revealed findings, violations, and additional items are summarized in the table below. Licensee-
identified non-cited violations (NCVs) are documented in report sections: 71153.
List of Findings and Violations
Essential Raw Cooling Water Pumps Inoperable due to Frozen Motor Bearing Cooling Lines
Cornerstone Significance Cross-cutting Report Section
Aspect
Mitigating Green None 71111.15 -
Systems NCV Operability
05000327, 328/2018001-01 Determinations
Closed and Functionality
Assessments
A self-revealing Green NCV of Technical Specification 5.4.1, Procedures, was identified
when Sequoyah/TVA did not establish, implement and maintain applicable procedures
recommended in Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing
Maintenance. Specifically, the essential raw cooling water (ERCW) pump motor maintenance
procedure, 0-MI-MRR-067-002.0, Removal/Disassembly/Reassembly Instruction for ERCW
Pumps does not contain specific direction for the slope of the motor bearing cooling supply
and return lines for the motor reassembly.
Improper Calibration of Reactor Trip Instrumentation Results in a Condition Prohibited by
Technical Specifications
Cornerstone Significance Cross-cutting Report
Aspect Section
Mitigating Green H.9 - Training 71153 -
Systems NCV Licensee
05000327/2018001-02 Event
Closed Reports
A self-revealing Green finding and associated NCV of Sequoyah Unit 1 Technical Specification 5.4, Procedures, was identified on June 25, 2016, when the licensee did not implement
procedures to calibrate Delta-T/Tavg Channel IV with the correct test equipment input
impedance settings, which resulted in Delta-T/Tavg Channel IV being out of technical
specifications allowed tolerances.
Enclosure
Additional Tracking Items
Type Issue number Title Report Status
Section
Licensee 05000327/2016-006-00 Improper Calibration of 71153 Closed
Event Reactor Trip
Report Instrumentation Results in
(LER) Condition Prohibited by
Technical Specifications
Type Issue number Title Report Status
Section
LER 05000327/2016-009-00 Manual Reactor Trip During 71153 Closed
Startup Due to a Control Rod
Misalignment
Type Issue number Title Report Status
Section
LER 05000327,05000328/ Breached Door Renders Both 71153 Closed
2017-001-00 Trains of the Auxiliary Building
Gas Treatment System
Type Issue number Title Report Status
Section
LER 05000327, 05000328/ Automatic Actuation of 71153 Closed
2017-002-00 Emergency Diesel Generators
Due to Loss of Power to 6.9kV
Shutdown Board
Enclosure
PLANT STATUS
Unit 1 began the inspection period at 100 percent rated thermal power (RTP). On February 5,
2018, operators reduced power to 25 percent RTP to remove the main turbine from service to
perform maintenance on the turbines electrohydraulic control system. The unit returned to 100
percent RTP on February 7, 2018, and remained there for the rest of the inspection period.
Unit 2 operated at or near 100 percent 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 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
71111.04 - Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Unit 1 and 2 ERCW, on January 23, 2018
(2) Unit 2 emergency diesel generator A starting air, on February 13, 2018
(3) Unit 2 component cooling water system A while component cooling water pump B was
out of service, on February 15, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of:
(1) Unit 1 and Unit 2 component cooling system, on March 26, 2018
71111.05AQ - Fire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Unit 2, auxiliary building - El. 669, on January 25, 2018
(2) Unit 1 and Unit 2, control building - El. 706, on January 25, 2018
(3) Unit 1 and Unit 2 , auxiliary building - El. 759, on February 15, 2018
Enclosure
(4) Unit 1 and Unit 2, auxiliary building - El. 714, on March 7, 2018
(5) Unit 1 and Unit 2, auxiliary building- El. 690, on March 26, 2018
71111.06 - Flood Protection Measures
Cables (1 Sample)
The inspectors evaluated cable submergence protection in:
(1) HH82 on February 21, 2018
(2) MH32A1, MH33, MH14A, MH24, and MH25 on February 21, 2018
71111.07 - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors observed the licensees component cooling water (CCS) 1A2 heat
exchanger inspection and the state of cleanliness of the heat exchanger plates on March 6,
2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated, Identification and Immediate Actions for a Faulted
Steam Generator Isolation and Steam Generator Tube Rupture on February 27, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated licensed operator performance in the main control
room during the unplanned Unit 1 downpower to 25 percent RTP on February 5, 2018, in
response to turbine control anomalies.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with
the following equipment and/or safety significant functions:
(1) Review of Sequoyahs thirteenth 10 CFR 50.65 (a)(3) periodic evaluation on March 16,
2018
(2) Review of Function 040-C, ERCW Equipment Room Sumps on March 16, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
Enclosure
(1) Unit 1 and Unit 2, week of January 14 - January 20, 2018, including protected
equipment status reviews for scheduled maintenance on the L-B ERCW pump and the
emergent inoperablity of P-B and M-B ERCW pumps due to loss of motor cooling
water flow
(2) Unit 1 elevated risk due to emergent main turbine controls malfunction and downpower
to 25 percent RTP to remove the turbine from service and perform corrective
maintenance, on February 5-7, 2018
(3) Unit 1 and Unit 2, week of March 4 - March 10, 2018, including protected equipment
status reviews for scheduled maintenance on the 1A component cooling system heat
exchanger and the emergent removal from service of the A common station service
transformer
(4) Unit 1 and Unit 2, week of March 19 - March 23, 2018, including protected equipment
status reviews for scheduled maintenance on the 2A safety injection pump
71111.15 - Operability Determinations and Functionality Assessments (5 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Unit 1 and 2, ERCW pump motor cooling lines susceptible to freezing, Condition Report
(CR)1380675, on January 29, 2018
(2) Unit 1 and 2, B-B ERCW SWP failed Section XI acceptance criteria, CR1379440, on
February 1, 2018
(3) Unit 1, SIS pump discharge to RWST valve nuts have less than full thread engagement,
CR 1384800, on February 26, 2018
(4) Unit 1, reactor trip breaker A abnormal light indications, CR1383922 on, March 21,
2018
(5) Unit 1 and 2, Incorrect sized breaker installed in plant, CR1388832, on March 28, 2018
71111.18 - Plant Modifications (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) SQN-1-2017-062-002, Crimp and Furminite CVCS drain line, on February 14, 2018
71111.19 - Post Maintenance Testing (5 Samples)
The inspectors evaluated the following post maintenance tests:
(1) Work Order (WO) 118594012, 6.9kv shutdown board loss of voltage, overvoltage and
degraded voltage relay calibration, on January 22, 2018
(2) WO 119368856, Remove A train SSPS from service to allow troubleshooting of blown
fuse for A reactor trip breaker shunt coil, on February 4, 2018
(3) WO 119229100, Install TMOD SQN-1-2017-062-002 to reduce unidentified RCS
leakage, on February 12, 2018
(4) WO 119191043, 1A component cooling system heat exchanger cleaning, on March 9,
2018
(5) WO 118828740, Belt inspection, fan bearing lube and clean of Spent Fuel Pool and
Thermal Barrier Booster Pump cooler B-B, on March 30, 2018
Enclosure
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (1 Sample)
(1) 1-SI-OPS-082-007.A, Electrical Power System Diesel Generator 1A-A, on February 26,
2018
In-service (2 Samples)
(1) 1-SI-SXP-063-201.A, Safety Injection Pump 1A-A Performance Test, on February 7,
2018
(2) 2-SI-SXP-074-201.B, Residual Heat Removal Pump 2B-B Performance Test, on
March 5, 2018
Reactor Coolant System Leak Detection (1 Sample)
(1) 0-SI-OPS-068-137.0, Unit 1 Reactor Coolant System Water Inventory, on
March 22, 2018
71114.06 - Drill Evaluation
Emergency Planning Drill (2 Samples)
(1) The inspectors evaluated the emergency preparedness drill on January 31, 2018. The
drill included:
- loss of the annunciator system
- a main feedwater pump tripping
- loss of offsite power with both emergency diesel generators not being available
(2) The inspectors evaluated the emergency preparedness drill on March 7, 2018. The
drill included:
- a reactor coolant system (RCS) unidentified leak of 33 gpm occurred
- an earthquake then happened damaging the 1B 6.9 KV Shutdown Board,
unisolable Main Steam line breaks on Steam Generators 1 and 4 occurred, a large
rupture to the RWST, and a small break LOCA.
pumps seized due to the shaking caused by the earthquake
- the use of the Severe Accident Management Guidelines (SAMG)
Enclosure
OTHER ACTIVITIES - BASELINE
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Reactor Trip Breaker A (RTA) abnormal light indications from a fuse failure, CR
1383922, on March 30, 2018
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (4 Samples)
The inspectors evaluated the following licensee event reports which can be accessed at
https://lersearch.inl.gov/LERSearchCriteria.aspx:
(1) LER 05000327/2016-006-00, Improper Calibration of Reactor Trip Instrumentation
Results in Condition Prohibited by Technical Specifications on September 12, 2016
(2) LER 05000327/2016-009-00, Manual Reactor Trip During Startup Due to a Control Rod
Misalignment, on February 27, 2017
(3) LER 05000327,05000328/2017-001-00, Breached Door Renders Both Trains of the
Auxiliary Building Gas Treatment System Inoperable, on April, 26, 2017
(4) LER 05000327, 05000328/2017-002-00, Automatic Actuation of Emergency Diesel
Generators Due to Loss of Power to 6.9kV Shutdown Board, on June 25, 2016
Personnel Performance (1 Sample)
The inspectors evaluated the loss of B train ERCW to both units and licensees
performance on January 18.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
International Atomic Energy Agency (IAEA) Operational Safety Review Team (OSART)
Assessment - August 14 - August 31, 2017
The International Atomic Energy Agency is an independent intergovernmental, science and
technology-based organization, in the United Nations family, that serves as the global focal
point for nuclear cooperation. One of the services provided is an independent assessment of
licensee performance by senior staff members from the IAEA member states. This assessment
team is called an Operational Safety Review Team, or OSART. The focus of the review by the
OSART is on the safety and reliability of plant operation through review of the operation of the
plant and the performance of TVAs management and staff. The NRC believes that it would be
beneficial for the U.S. Nuclear power industry to continue to volunteer and participate in the
OSART missions. To help ensure that U.S. licensees participate in the operational safety
assessment review team missions, the NRC has decided to and will grant a one-time regulatory
inspection credit (a reduction in the baseline program) for those baseline programs that overlap
with the OSART review as directed and outlined in Manual Chapter 2515, Section 08.05,
Enclosure
Baseline Inspection Credit for Operational Safety Review Team Effort, dated March 28, 2017.
Between August 14 and August 31, 2017, TVA personnel debriefed the inspectors about issues
identified by the OSART assessment team on a daily basis. The inspectors also participated in
weekly OSART team leader debriefs and the OSART team exit on August 31, 2017. The
inspectors used the information provided during the daily and weekly debriefs and the final
OSART exit meeting to screen the issues identified by OSART for immediate safety concerns.
None were identified.
NRC inspectors reviewed both a draft and final version of the OSART report. Inspectors
screened the issues documented in the reports to identify issues that required additional
NRC review in accordance with the reactor oversight process. Issues identified as requiring
additional NRC follow-up will be reviewed by inspectors during routine baseline inspection
activities. Findings identified will be documented in applicable NRC inspection reports.
Based on the results of the inspectors review and assessment of the scope of OSART activities
through the debriefs and the review of the draft and final OSART mission report, NRC Region II
management approved for Sequoyah regulatory inspection credit in the baseline inspection
procedures described in Section 08.05 of Inspection Manual Chapter (MC) 2515. Based on the
summary of radiation safety-related inspection activities documented in the OSART draft and
final report and radiation protection activities observed during the OSART inspection, radiation
safety inspection activities for Sequoyah will be credited 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />. The inspectors determined
that due to the timing of the issuance of the final OSART mission report, providing credit for
emergency preparedness inspections that will not be performed until September 2019, did not
meet the intent of the credit guidelines established in IMC 2515; therefore the hours credited to
emergency preparedness inspection activities for Sequoyah will be zero. Inspection areas
contained within the NRC inspection procedures (IP 71111.22 and IP 71111.05AQ) are not
documented in the report therefore hours credited to Surveillance Testing and Fire Protection
inspection activities for Sequoyah will be zero. Full regulatory inspection credit for the IP
71152B, Problem Identification & Resolution as described in IMC 2515 of 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> will be
credited based on the OSART. The NRC has made the final OSART report publicly available
on the NRC website, Agency Documents Access and Management System (ADAMS) accession
number ML18061A036.
Enclosure
INSPECTION RESULTS
Observation 71152 - Annual
Follow-up of
Selected Items
Annual Follow-up of Selected Issues: Reactor Trip Breaker abnormal light indications caused
by a fuse failure
The inspectors conducted a detail review of CR 1383922, Reactor Trip Breaker A (RTA)
abnormal light indications from a fuse failure. The inspectors chose this sample due to a
number of issues the site has had regarding Bussmann KWN and KTN type fuses dating back
to 2011 and a 2005 Part 21 report on these type fuses from Bussmann. For CR 1383922, the
licensee determined that inadequate heating during the manufacturing process caused a poor
solder connection, thus causing the fuse to open up inadvertently. The failure caused by a
manufacturing defect was previously identified by review of the 2005 Part 21 report and by a
Root Cause performed in 2011. The inspectors reviewed the licensees corrective actions to
evaluate the population of Bussmann fuses installed in the plant and risk rank replacement of
these fuses with a different kind. The inspectors determined that the licensees plan to
address this issue was reasonable commensurate with the safety significance of equipment
that might be affected by these type of fuses.
Licensee Identified Non-Cited Violation 71153 -
Licensee
Event
Reports
This violation of very low safety significant was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a Non-Cited
Violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Sequoyah Unit 1 and Unit 2 Technical Specification 3.7.12, Auxiliary Building Gas
Treatment System (ABGTS), requires two ABGTS trains be operable in modes 1, 2, 3, and 4.
Contrary to the above, from March 3-7, 2017, the licensee blocked open door A212 resulting
in the inoperability of the auxiliary building secondary containment enclosure boundary and
thus inoperability of both trains of the ABGT
- S.
Significance/Severity Level: Green. Using Inspection Manual Chapter 0609, Appendix A,
The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012,
the inspectors determined that this finding was of very low safety significance (Green)
because the finding only represents a degradation of the radiological barrier function provided
for the auxiliary building.
Corrective Action Reference: CR1269767
Essential Raw Cooling Water Pumps Inoperable due to Frozen Motor Bearing Cooling Lines
Cornerstone Significance Cross-cutting Report Section
Aspect
Mitigating System Green None 71111.15 -
Enclosure
NCV Operability
05000327/328/2018001-01 Determinations
Closed and Functionality
Assessments
A self-revealing Green NCV of Technical Specification 5.4.1, Procedures, was identified
when Sequoyah/TVA did not establish, implement and maintain applicable procedures
recommended in Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing
Maintenance. Specifically, the ERCW pump motor maintenance procedure, 0-MI-MRR-067-
2.0, Removal/Disassembly/Reassembly Instruction for ERCW Pumps does not contain
specific direction for the slope of the motor bearing cooling supply and return lines for the
motor reassembly.
Description On January 18, 2018, at 0121, with ambient temperature below freezing, the
licensee placed M-B ERCW Pump in service and removed L-B ERCW pump from service
for maintenance. At 0342, operators started P-B ERCW pump and secured M-B ERCW
pump due to increasing motor bearing temperatures on the M-B ERCW pump. P-B ERCW
pump subsequently had increasing motor bearing temperatures. Operators started N-B
ERCW pump and stopped P-B ERCW pump. At 0615, the B ERCW header was declared
inoperable on both units due to the inoperability of L-B, M-B and P-B ERCW pumps.
ERCW pump motor bearing cooling is supplied from the pump discharge. The pump motor
bearing cooling lines were originally heat traced to ensure water in the line would not freeze
when a pump was not running and ambient temperatures were below freezing. ERCW motor
bearing cooling was redesigned in 1989 to remove heat tracing and to slope the motor cooling
lines such that the motor cooling water lines would self-drain, and thus be free of water and
not susceptible to freezing when the pump is not in service. However, licensee procedure,
0-MI-MMR-067-002.0, Removal/Disassembly/Reassembly Instruction for ERCW Pumps did
not incorporate guidance to ensure the proper slope of the ERCW pump motor bearing
cooling lines following maintenance such that the lines would self-drain. Inspection
determined that five of the eight ERCW pumps J-A, K-A and pumps M-B, N-B and P-B
all had improperly sloped motor cooling lines that allowed water to remain in the lines when
the pumps were not running.
Corrective Actions: On January 18, licensee personnel mobilized temporary heat tracing and
480V space heaters to thaw the ERCW pump motor bearing cooling water lines. On
January 18 at 1345, P-B ERCW pump was restored to operable status following a pump run
and verification of acceptable motor bearing cooling flow and bearing temperatures. This
restored B train ERCW to operable status. As an interim action, the licensee implemented
Standing Order SO-18-003 to address the improper slopes for the motor cooling lines, and
have operators declare the ERCW J-A, K-A, M-B, N-B, and P-B pumps inoperable when
outside air temperatures are below freezing unless the pumps are in service. The licensee
completed corrective maintenance to ensure proper slope on all ERCW pump motor cooling
water piping on February 16, 2018.
Corrective Action Reference: : CR1380675, CR1378392, CR1378822, CR1378392
Performance Assessment:
Performance Deficiency: The licensees failure to ensure ERCW motor maintenance
procedure, 0-MI-MRR-067-002.0, Removal/Disassembly/Reassembly Instruction for ERCW
Pumps contained specific direction for the slope of the motor cooling supply and return lines
for the motor reassembly was a performance deficiency.
Enclosure
Screening: The performance deficiency was associated with the maintenance procedure
quality attribute of the mitigating system cornerstone and adversely affected the cornerstone
objective to ensure the availability, reliability, and capability of the ERCW system to respond
to an initiating event and prevent undesirable consequences. Specifically, the failure to
ensure the ERCW motor maintenance procedure contained direction for the slope of the
motor cooling supply and return lines resulted in the loss of motor cooling water flow that
rendered standby ERCW pumps inoperable during ambient freezing conditions.
Significance: In accordance with Inspection Manual Chapter (IMC) 0609 Attachment 4
Initial Characterization of Findings, dated October 7, 2016, this finding affected the
mitigating systems cornerstone because ERCW provides the ultimate heat sink which impacts
core decay heat removal. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the
inspectors determined that this finding was of very low safety significance (Green) because
the finding (1) was not a deficiency affecting the design and qualification of a mitigating
structure, system, or component, and did not result in a loss of operability or functionality, (2)
did not represent a loss of system and/or function, (3) did not represent an actual loss of
function of at least a single train for longer than its allowed outage time, or two separate
safety systems out-of-service for longer than their technical specification allowed outage time,
and (4) did not represent an actual loss of function of one or more non-technical specification
trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in
accordance with the licensees maintenance rule program.
Cross-cutting Aspect: The inspectors did not assign a cross-cutting aspect because the
finding did not reflect present licensee performance because the failure to update this
licensee maintenance procedure with design requirement from the design change occurred
outside the three year window.
Enforcement:
Violation: Sequoyah Technical Specification 5.4.1, Procedures, requires, in part, that
procedures be established, implemented and maintained for the applicable procedures
recommended in Regulatory Guide 1.33, Appendix A, dated February 1987. Regulatory
Guide 1.33, Section 9.a, requires, in part, that maintenance that can affect the performance of
safety-related equipment should be properly performed in accordance with written procedures
appropriate to the circumstances.
Contrary to the above, from May 1989 until January 2018, the licensee did not maintain
procedures for maintenance on ERCW pumps appropriate to the circumstance; specifically,
procedures to reassemble ERCW pumps lacked instructions to ensure the correct slope for
the motor bearing cooling lines was maintained.
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the
Enclosure
NCV 5000327/2018001-01; Improper Calibration of Reactor Trip Instrumentation Results in a
Condition Prohibited by Technical Specifications
Cornerstone Significance Cross-cutting Report
Aspect Section
Mitigating Green H.9 - Training 71153 -
Systems NCV Licensee
05000327/328/2018001-02 Event
Closed Reports
A self-revealing Green finding and associated NCV of Sequoyah Unit 1 Technical Specification 5.4, Procedures, was identified on June 25, 2016, when the licensee did not
implement procedures to calibrate Delta-T/Tavg Channel IV with the correct test equipment
input impedance settings, which resulted in Delta-T/Tavg Channel IV being out of technical
specifications allowed tolerances.
Description: On June 23, 2016, the digital filter processor card associated with Unit 1 Delta-
T/Tavg channel IV failed and operators declared Delta-T/Tavg channel IV inoperable. The
card was replaced on June 24, 2016, and a channel calibration was performed prior to
returning the channel to operable status. The normal measuring and test equipment (MTE)
used to perform this calibration was not available. Maintenance personnel instead used a
Fluke 8845
this instrument has a different default input impedance setting than the MTE. Maintenance
personnel performing the calibration were unaware of the default input impedance difference
and the procedure did not identify and require the use of the correct internal impedance
setting. As a result, licensee procedure 1-SI-IFT-068-067.4, Functional Test of T/TAVG
Channel IV Rack 13 Loop 1-T-68-67 (T-441/442), was performed with the test
instrumentation impedance setting not set correctly and resulted in Delta-T/Tavg Channel IV
being adjusted incorrectly and out of technical specifications allowed tolerances. Operations
personnel declared Delta-T/Tavg Channel IV operable on June 25 at 0215 based on the
improper calibration. On June 27, 2016, licensee reactor engineers noted Tavg had taken a
two-degree step change lower following the digital filter card replacement and the licensee
began investigation and identified the incorrect input impedance was used during previous
performance of the Delta-T/Tavg Channel IV calibration. On June 29 at 23:30, Delta-T/Tavg
Channel IV was returned to operable status following calibration and functional testing using
MTE with appropriately configured input impedance.
Corrective Actions: The licensee performed the calibration and functional testing of Delta-
T/Tavg Channel IV with the correct input impedance to restore compliance on June 29, 2016.
The licensee has revised calibration procedures to ensure the correct impedance settings are
used.
Corrective Action Reference: CR 1187308
Performance Assessment:
Performance Deficiency: The licensees failure to ensure the test equipment used to perform
calibration of Delta-T/TAVG Channel IV was configured to the appropriate input impedance
was a performance deficiency.
Screening: This performance deficiency was associated with the mitigating systems
Enclosure
cornerstone and was more than minor because it adversely affected the cornerstone
objective to ensure availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences. Specifically, licensee personnel use of the
Fluke 8845A with the incorrect input impedance setting resulted in the inoperability of reactor
protection system input signals.
Significance: This performance deficiency was associated with the mitigating systems
cornerstone. The inspectors screened this finding using IMC 0609, Appendix A, The
Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012.
Because all three questions in Section C of Exhibit 2, Mitigating Systems Screening
Questions, were answered no, the finding screened as Green.
Cross-cutting Aspect: The inspectors determined that the finding has a cross-cutting aspect
of training in the human performance area because licensee personnel had not been trained
on the use of the Fluke 8845A and were not aware of the difference in default input
impedance settings. (H.9)
Enforcement:
Violation: Violation: Sequoyah Unit 1 Technical Specification 5.4.1 requires, in part, that
procedures shall be established, implemented, and maintained covering the applicable
procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Appendix A, section 9.a requires, in part, that maintenance of safety-
related equipment is performed in accordance with written procedures appropriate to the
circumstances.
Contrary to the above, on June 25, 2016, the licensee did not implement procedures to
calibrate Delta-T/Tavg Channel IV with the correct test equipment input impedance settings.
The licensee restored compliance on June 29, 2016 by performing the calibration and
functional testing of Delta-T/Tavg Channel IV with the correct input impedance settings.
Disposition: 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 April 5, 2018, the inspector presented the quarterly resident inspector inspection results
to Mr.
- D. Dimopoulos, and other members of the licensee staff.
Enclosure
DOCUMENTS REVIEWED
Procedures
0-SO-67-1, Essential Raw Cooling Water, Revision 109
2-SO-70-1, Att.3, Component Cooling Water System A Train Valve Checklist 2-70-1.03,
December 31, 2012
0-SO-30-10 Att. 9, Auxiliary Building Ventilation Systems, Plant Operability Impacts
(Tech Spec/TRM) Associated with ESF Coolers, August 22, 2016
0-SO-82-7, Diesel Generator 2A-A Support Systems, Revision 25
Procedures
Sequoyah Fire Protection Report, Part II - Fire Protection Plan, Revision 36
PFP NO: AUX-0-669-00, Fire Protection Pre-Fire Plans Auxiliary Building - El. 669, Revision 4
PFP NO: AUX-0-669-02, Fire Protection Pre-Fire Plans Auxiliary Building - El. 669 (Unit 2
Side), Revision 10
PFP NO: AUX-0-669-03, Fire Protection Pre-Fire Plans Auxiliary Building - El. 669 (Unit 1
Side), Revision 7
B87 150915 003, SQN Combustible Loading Calculation for Room 669.0-A01, Revision 5
PFP NO: CON-0-706-00, Fire Protection Pre-Fire Plans Control Building - El. 706, Revision 7
MMTP-102, Erection of Scaffolds/Temporary Work Platforms and Ladders, Revision 14
SQN-DC-V-1.3.4, Category 1 Cable Tray Support Systems, August 20, 1975
B87 960829 003, Guidelines for the Erection of Scaffolding, Revision 2
PFP NO: AUX-0-749-00, Fire Protection Pre-Fire Plans Auxiliary Building - El. 749 & 759,
Revision 4
PFP NO: AUX-0-749-01, Fire Protection Pre-Fire Plans Auxiliary Building - El. 749 (Unit 1
Side), Revision 9
PFP NO: AUX-0-749-02, Fire Protection Pre-Fire Plans Auxiliary Building - El. 749 (Unit 2
Side), Revision 10
Condition Reports
1383239, Housekeep issue Unit 2 AB El 669
1343240, NRC observation of Pre-Fire Plans
1380273, NRC Identified: Ladder installed without appropriate evaluation/approval
Procedures
SQN-0-MNWY-317-HH3, PM#052053000, Attachment A
Work Orders
Procedures
0-TI-SXX-000-146.0, Program for Implementing NRC Generic Letter 89-13, Revision 4
0-MI-MRR-070-611.0, Component Cooling System Heat Exchanger Maintenance, Revision 12
Work Orders
E-0, Reactor Trip or Safety Injection, Revision 39
E-2, Faulted Steam Generator Isolation, Revision 16
E-3, Steam Generator Tube Rupture, Revision 23
CR1303568, Unit 2 Turbine and Rx Shutdown due to main turbine drain line steam break
Procedures
TI-4, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting -
10CFR50.65, Revision 30
Procedures
NPG-SPP-07.3, Work Activity Risk Management Process, Revision 22
NPG-SPP-07.2.4, Forced Outage or Short Duration Planned Outage Management, Revision 7
NPG-SPP-07.2, Outage Management, Revision 8
Procedures
NEDP-22, Operability Determinations and Functional Evaluations, Revision 18
OPDP-8, Operability Determination Processes and Limiting Conditions for Operation Tracking,
Revision 24
0-SI-SXP-067-202.B, ERCW Traveling Screen Wash Pump B-B Performance Test, Revision 13
Functionality Evaluation Documentation for CR 1265450 & 1379440, dated January 23, 2018
Condition Reports
1379440, B-B ERCW SWP failed Section XI acceptance criteria
1384033, perform extent of condition review for part 21 report
Work Orders
118629224
119368807
Procedures
NPG-SPP-09.3, Plant Modifications and Engineering Change Control, Revision 27
NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments, Revision 12
NPG-SPP-09.5, Temporary Modifications Temporary Configuration Changes, Revision 12
Procedures
NPG-SPP-06.3, Pre-/Post-Maintenance Testing, Revision 1
NPG-SPP-06.9, Testing Programs, Revision 1
NPG-SPP-06.9.1, Conduct of Testing, Revision 10
NPG-SPP-06.9.3, Post-Modification Testing, Revision 9
1-SI-OPS-202-253.A, Function Test of Loss of Voltage Relays On 6.9KV Shutdown Board 1A-A,
Revision 20
Work Orders
WO119341490
rocedures
NPG-SPP-06.9.1, Conduct of Testing, Revision 10
1-SI-SXP-063-201.A, Safety Injection Pump 1A-A Performance Test, Revision 21
1-SI-OPS-082-007.A, Electrical Power System Diesel Generator 1A-A, Revision 66
2-SI-SXP-074-201.B, Residual Heat Removal Pump 2B-B Performance Test, Revision 17
Work Orders
WO118691071
Procedures
EPIP-1, Emergency Plan Classification Matrix, Revision 52
EPIP-2, Notification of Unusual Event, Revision 35
EPIP-3, Alert, Revision 37
EPIP-4, Site Area Emergency, Revision 39
EPIP-5, General Emergency, Revision 48
Procedures
NPG-SPP-22.300, Corrective Action Program, Revision 10
NPG-SPP-22.303, CR Actions, Closures and Approvals, Revision 10
Operator Chronological Logs
AOP-C.01 Rod Control Malfunctions, Revision 26
0-MI-EBR-202-007.5, 6.9kV ABB Type 7.5 HK Breaker Inspection, Revision 0001
NPG-SPP-06.14 TROUBLESHOOTING PLAN
CR 1299591, Unit Board 28 Breaker 1814 Failed Open During Shutdown board 2A-A Transfer
Enclosure