IR 05000327/2017009

Sequoyah Nuclear Plant - NRC Problem Identification and Resolution Inspection Report 05000327/2017009, 05000328/2017009

ML17216A345
Person / Time
Site:	Sequoyah
Issue date:	08/04/2017
From:	Reinaldo Rodriguez NRC/RGN-II
To:	Shea J W Tennessee Valley Authority
References
IR 2017009
Download: ML17216A345 (14)

Text

August 4, 2017

Mr. Joseph Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 3R-C Chattanooga, TN 37402-2801

SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000327/2017009, 05000328/2017009

Dear Mr. Shea:

On June 22, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Sequoyah Nuclear Plant Units 1 and 2 and discussed the results of this inspection with Mr. Anthony Williams and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.

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

The team also evaluated the plant's processes for use of industry and NRC operating experience information and the effectiveness of the plant's audits and self-assessments. Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the plant's programs to establish and maintain a safety-conscious work environment, and interviewed plant personnel to evaluate the effectiveness of these programs. Based on the team's observations and the results of these interviews the team found no evidence of challenges to your organization's safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. The NRC inspectors did not identify any findings or violations of more than minor significance.

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 Witholding."

Sincerely,/RA Frank Ehrhardt Acting for/ Reinaldo Rodriguez, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79

Enclosure:

IR 05000327/2017009 and 05000328/2017009

w/Attachment:

Supplemental Information

Distribution via ListServ

ML17216A345 OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP NAME BBishop BCollins RTaylor SNinh SSeaton RRodriguez /RA FJE/ DATE 7/25/2017 7/17/2017 7/25/2017 7/21/2017 8/4/2017 8/4/2017 OFFICE RII:DRP NAME FEhrhardt DATE 8/4/2017 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79

Report Nos.: 05000327/2017009 and 05000328/2017009 Licensee: Tennessee Valley Authority (TVA)

Facility: Sequoyah Nuclear Plant, Units 1 and 2 Location: Sequoyah Access Road Soddy-Daisy, TN 37379 Dates: June 5, 2017 through June 22, 2017

Inspectors: S. Seaton, Project Engineer, Team Leader R. Taylor, Senior Project Inspector S. Ninh, Senior Project Engineer B. Bishop, Project Engineer B. Collins, Reactor Inspector Approved by: R. Rodriguez, Chief Reactor Projects Branch 7 Division of Reactor Projects

SUMMARY

IR 05000327/2017009 and 05000328/2017009; June 5, 2017 - June 22, 2017; Sequoyah Nuclear Plant Units 1 and 2; Biennial Problem Identification and Resolution report.

The inspection was conducted by a senior project inspector, a senior project engineer, two project engineers, and a reactor inspector. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6. 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 (OE) usage was found to be generally acceptable and integrated into the licensee's 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

4OA2 Problem Identification and Resolution

.1 Assessment of the Corrective Action Program

a. Inspection Scope

The inspectors reviewed the licensee's CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of the problem investigation program. To verify that problems were properly identified, appropriately characterized and entered into the CAP, the inspectors reviewed Nuclear Condition Reports (CRs) that were issued between June 2015 and June 2017, including a detailed review of selected CRs associated with the following risk-significant systems:

the Control Air System, the Heating Ventilation and Air Conditioning (HVAC) System, and the Emergency Diesel Generators. 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 NRC's Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, emergency preparedness and security. These CRs were reviewed to assess each department's threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions (CAs). The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs 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 within the selected systems listed above and other plant areas to assess the material condition and to identify any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, CAs, completed work orders (WOs) 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 walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review selected CRs 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 CRs and the guidance in licensee procedures NPG-SPP-22.306, "Level 1 Evaluation,"

Revision 0006 and NPG-SPP-22.305, "Level 2 Evaluation," Revision 0006. The inspectors assessed if the licensee had adequately determined the cause(s) 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 reviewed selected industry OE items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRC's assessment of the licensee's CAP.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Plant Screening Committee meetings and Management Review Committee (MRC) meetings.

Documents reviewed are listed in the Attachment.

b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure NPG-SPP-300, "Corrective Action Program," Revision 0008, in addition to management's expectation that employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.

Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensee's CAP procedures as described in the CR severity level determination guidance in NPG-SPP-300. Each CR was assigned a priority level at the MRC meeting and adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that plant personnel had conducted root cause and apparent cause analyses in compliance with the licensee's CAP procedures and assigned cause determinations were appropriate, considering 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 procedures.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that, 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, in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence were sufficient to ensure corrective actions were properly implemented and were effective.

c. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors examined the licensee's use of industry OE to assess the effectiveness of the plant. In addition, the inspectors selected OE documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal OE items, etc.) which had been issued since June 2015, to verify whether the licensee had appropriately evaluated each notification for applicability to the Sequoyah Nuclear Plant, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.

b. Assessment Based on a review of selected documentation related to operating experience issues, the inspectors determined that the licensee was generally effective in screening OE for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes.

Operating experience issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in all root cause evaluations in accordance with licensee procedure NPG-SPP-22.306.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. 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-22.102, "NPG Self-Assessment and Benchmarking Programs," Rev. 0002.

b. Assessment The inspectors determined that the scopes of assessments and audits were adequate.

Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspector's independent reviews. The inspectors verified that CRs 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.

c. Findings

No findings were identified.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

During the course of the inspection, the inspectors assessed the plant's safety-conscious work environment through review of the plants employee concerns program (ECP) and interviews with various departmental personnel. The inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

b. Assessment Based on the interviews conducted and the CRs reviewed, 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.

Based on discussions conducted with a sample of plant employees from various departments, 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.

c. Findings

No findings were identified.

4OA6 Exit

Exit Meeting Summary

On June 22, 2017, the inspectors presented the inspection results to Mr. A. Williams 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

A. Williams, Site Vice President

B. Basham, Performance Improvement Manager

M. McBrearty, Site Licensing Manager

S. Bowman, Site Licensing Engineer

P. Parashek, Operations Senior Reactor Operator

M. Randolph, Performance Improvement

L. Williams, Performance Improvement

LIST OF REPORT ITEMS

Opened and Closed

None

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

Procedures

NPG-SPP-01.16, Condition Report Initiation, Rev. 0000

NPG-SPP-03.4, Maintenance Rule Performance Indicator Monitoring, Trending and Reporting -

10CFR50.65, Rev. 0003

NPG-SPP-01.7.1, Employee Concerns Program, Rev. 0001

NPG-SPP-06.2, Preventive Maintenance, Rev. 0011

NPG-SPP-07.1.4, Work Management Prioritization - On Line, Rev. 0006

NPG-SPP-09.3, Plant Modifications and Engineering Change Control, Rev. 0024

NPG-SPP-09.20, Vendor Manual Control, Rev. 0005

NPG-SPP-09.16.1, System, Component and Program Health, Rev. 0010

NPG-SPP-22.102, NPG Self-Assessment and Benchmarking Programs, Rev. 0002

NPG-SPP-22.300, Corrective Action Program, Rev. 0008

NPG-SPP-22.302, Corrective Action Program Screening, Rev. 0010

NPG-SPP-22.303, CR Actions, Closures and Approvals, Rev. 0008

NPG-SPP-22.305, Level 2 Evaluation, Revision 0006

NPG-SPP-22.306, Level 1 Evaluation, Rev. 0006

NPG-SPP-22.500, Operating Experience Program, Rev. 0003

NEDP-8.0, Evaluations for Procurement of Materials, Items, and Services, Rev. 0002

NEDP-22, Operability Determinations and Functional Evaluations, Rev. 0017

NEDP-27, Past Operability Evaluations, Rev. 0003

OPDP-1, Conduct of Operations, Rev. 0038

OPDP-8, Operability Determination Process and Limiting Conditions for Operation Tracking, Rev. 0023 17-SBE-026-023, Engineering Work Request: Evaluate Acceptability of Debris in the Fire

Protection Piping, Rev. 1

M&AI-7.1, Cable Terminations and Repairing Damaged Cables, Rev.33

0-PI-FPU-317-299.W, Fire Protection Miscellaneous Inspections, Revision 0044

TI-4, Maintenance Rule Performance Indicator Monitoring, Trending and Reporting -

10CFR50.65, Rev. 0029 OPL273C1626, Cycle 16-4 Plant Status Update (Licensed Operator Training), dated 6/13/16

OPL273C1636, Cycle 16-5 Plant Status Update (Licensed Operator Training), dated 8/1/16

OPL273C1707, Cycle 17-2 Plant Status Update (Licensed Operator Training), dated 2/27/17

OPN222C1640, Plant Status Update (OE from SQN Voltage Regulator Trips), dated 6/8/16

SO-16-008, Sequoyah Fire Operations Department Standing Order, Increased Walk-Downs for Fire Areas Potentially Impacted by Trend of Debris in HPFP Non-Draining Sections, dated

11/27/2016

SO-16-103, Sequoyah Operations Department Standing Order, Compensatory Actions for D/G

Bldg Tornado Vulnerabilities, dated 05/16/2016

Condition Reports

1040168

1044251

1044255

1062507

1117466

1119661

1119663

1143804

1144342

1148228

1148543

1151352

1155763

1163235

1164452

1164446

1166927

1174405

1117456

1175834

1177144

1180402

1183201

1183350

1186385

1188774

214460

27479

239449

1242395

1289543

29296

1034503

1034504

1036980

1039545

1041093

1044530

1052611

1053615

1058327

1058754

1064736

1084292

1084294

1086421

1089802

1093946

1105025

1107364

1108257

1108270

1109158

1109400

1111730

1112088

1114858

1117470

1149169

1150202

1157650

1159677

1162711

1170545

1170721

1171143

1171265

1171811

1172955

1178891

1179126

1181710

1182472

1183093

1198163

1198170

206136

206142

206145

1206148

1222814

26511

29204

29213

29221

1230505

1237160

239748

239849

240993

1245204

1248045

250669

251829

254414

262587

1265577

1266643

271866

282928

1284205

1289625

1292997

1295662

1039485

1039545

1040168

1040619

1041370

1041787

1042155

1042919

1043817

1044831

1046074

1050108

1056760

1056796

1059220

1063266

1063399

1067941

1068000

1074991

1075135

1087006

1091218

1091675

1104481

1127022

1134056

1151732

1155285

1171371

1171811

1178891

1198155

1202710

1204345

1210565

1210595

1230951

1232336

1253437

1254414

1255707

1255800

1260873

1262322

1262323

1263606

1271796

1284668

1289929

1254101

1045080

1060847

1232494

1146638

1275616

1144824

1031280

1059536

1096404

1111677

206882

212994

1143804

1167448

1181710

1076179

297498

276635

292256

1289349

1281609

291042

289328

1110460

1115030

1101732

1085879

1085848

20225

1116316

1115221

1093348

1100725

1102444

1098901

1174406

1135308

1103389

1016839

1070076

1117468

1085005

1082712

1103382

1083349

1149872

1155352

1074347

1063258

1095026

Condition Reports

Generated

1305227, Develop and submit a licensing amendment request to NRC to remove kirk key interlock from 480 V ERCW MCC breakers

1306151, Evaluate need for more clear guidance for documenting Operations Management periodic review of operator workarounds, burdens, and challenges

1309730, SDBR chiller TCB adjustment PM performance was NA'd more than two times

1309574, Possible galvanic corrosion on drain nozzle of A-A MCR chiller condenser

1309286, Evaluate if a process for ensuring future changes to the diesel generators are evaluated for design bases tornado effects is necessary

1308624, Maximo auto populates the discovery date field when a CR is initiated and remains unless altered by the initiator

1305148, Evaluate if there is a potential vulnerability in the CR initiation process related to the timeliness of when Operations conducts their reviews

1305166, Evaluate software controls surrounding the ability to alter CR details once a CR is initiated

Work Orders

116906503

117015332

117088253

117124473

117176358

117406363

117431751

117434676

117440586

117459392

117470238

117554876

117581739

117823147

117823150

117823154

117990153

118024597

118279373

118284379

118296319

118388469

118497195

118703684

116705902

118101414

118101417

118101419

118101421

118551379

118753107

Self-Assessments

SQN-PI-FSA-15-002, 2015 INPO Mid-Cycle Focused Self Assessment

SQN-PI-SSA-16-013, Follow-Up Assessment CAP Quality

SQN-PI-SSA-17-003, Monthly SQN Corrective Action Program Audit - November

Other Documents

AFW system health report

HVAC system health report DCN D23085A, Corrective Action

1076179 revised 50.59 Auxiliary Building, Containment, and EDG Ventilation System Cooler Coil Replacement Project

Control Air System Diagram, OPT200.CSA SB

HO-2, Rev.5

Maintenance Rule Expert Panel Meeting Minutes, May 26, March 24, and February 5, 2016

SSCs in Alert Status- 5/21/17 Plant Screening Committee Meeting Agenda, June 7, 2017 Management Review Committee Meeting Agenda, July 28, 2016

Management Review Committee Meeting Agenda, June 8, 2017

MRC Meeting Minutes, July 28, 2016

GAP Analysis for

CRs 1103389 and

1016839 GAP Analysis for CR 1174406