ML14038A346

IR 05000327-13-005, 05000328-13-005; 10/1/2013 - 12/31/2013; Sequoyah Nuclear Plant, Units 1 and 2; Other Activities

ML14038A346
Person / Time
Site:	Sequoyah
Issue date:	02/07/2014
From:	Bartley J Reactor Projects Region 2 Branch 6
To:	James Shea Tennessee Valley Authority
References
IR-13-005
Download: ML14038A346 (44)

See also: IR 05000327/2013005

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

February 7, 2014

Mr. Joseph W. Shea

Vice President, Nuclear Licensing

Tennessee Valley Authority

1101 Market Street, LP 3D-C

Chattanooga, TN 37402-2801

SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT

05000327/2013005 AND 05000328/2013005

Dear Mr. Shea:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Sequoyah Nuclear Plant, Units 1 and 2. On January 13, 2014, the NRC

inspectors discussed the results of this inspection with Mr. Carlin and other members of your

staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one self-revealing finding of very low safety significance (Green) in

this report. This finding involved a violation of NRC requirements. The NRC is treating this

violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement

Policy.

If you contest the violation or significance of this NCV, 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, D.C. 20555-0001; with

copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, D.C. 20555-0001; 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 Regional Administrator, Region II, and the NRC Resident Inspector at the

Sequoyah Nuclear Plant.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of

cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting

aspects identified in CY 2014 will be coded under the latest revision to Inspection Manual

Chapter (IMC) 0310. Cross-cutting aspects identified in the last six months of 2013 using the

previous terminology will be converted to the latest revision in accordance with the cross-

reference in IMC 0310. The revised cross-cutting aspects will be evaluated for cross-cutting

themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with

the CY 2014 mid-cycle assessment review.

J. Shea 2

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections,

Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRCs Public Document Room or from the Publicly Available Records (PARS) component of

NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is

accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Jonathan H. Bartley, Chief

Reactor Projects Branch 6

Division of Reactor Projects

Docket Nos.: 50-327, 50-328

License Nos.: DPR-77, DPR-79

Enclosure: Inspection Report 05000327/2013005, 05000328/2013005

w/Attachment: Supplementary Information

cc: via ListServ distribution

_________________________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED

OFFICE RII:DRP RII:DRP RII:DRS RII:DRS RII:DRS RII:DRS RII:DRP RII:DRP

SIGNATURE JHB /RA for/ Via email BRB /RA for/ ORL /RA for/ BRB /RA for/ BRB /RA for/ JDH /RA/ JHB /RA/

NAME GSmith WDeschaine MSpeck LLake RHamilton RKellner JHamman JBartley

DATE 02/07/2014 02/07/2014 02/07/2014 02/07/2014 02/07/2014 02/07/2014 02/07/2014 02/07/2014

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

J. Shea 3

Letter to J.W. Shea from Jonathan H. Bartley dated February 7, 2014

SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT

05000327/2013005 AND 05000328/2013005

Distribution w/encl:

C. Evans, RII

L. Douglas, RII

OE Mail

RIDSNRRDIRS

PUBLIC

RidsNrrPMSequoyah Resource

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos.: 50-327, 50-328

License Nos.: DPR-77, DPR-79

Report Nos.: 05000327/2013005, 05000328/2013005

Licensee: Tennessee Valley Authority (TVA)

Facility: Sequoyah Nuclear Plant, Units 1 and 2

Location: Sequoyah Access Road

Soddy-Daisy, TN 37379

Dates: October 1 - December 31, 2013

Inspectors: G. Smith, Senior Resident Inspector

W. Deschaine, Resident Inspector

M. Speck, Senior Emergency Preparedness Inspector (Sections

1R04.1 and 1R05)

L. Lake, Senior Reactor Inspector (Section 1R08)

R. Hamilton, Senior Health Physicist (Section 2RS8)

R. Kellner, Health Physicist (Sections 2RS1, 4OA1)

Approved by: Jonathan H. Bartley, Chief

Reactor Projects Branch 6

Division of Reactor Projects

Enclosure

SUMMARY

IR 05000327/2013-005, 05000328/2013-005; 10/1/2013 - 12/31/2013; Sequoyah Nuclear Plant,

Units 1 and 2; Other Activities

The report covered a three-month period of inspection by resident inspectors and announced

inspections by regional inspectors. One self-revealing finding was identified. The significance

of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual

Chapter (IMC) 0609, "Significance Determination Process," (SDP) dated June 2, 2011. Cross-

cutting aspects are determined using IMC 0310, Components Within the Cross-Cutting Areas,

dated October 28, 2011. The NRC's program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4,

dated December 2006.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green: A self-revealing non-cited violation of 10 CFR 50 Appendix B, Criterion XVI,

Corrective Action, was identified for the licensees failure to promptly correct a

condition adverse to quality within a reasonable time. Timely corrective actions were not

taken to correct a dual position indication (open and closed lights both illuminated) on

the Unit 1 A train residual heat removal (RHR) containment sump suction flow control

valve (FCV) 1-FCV-63-72. This licensee entered this issue into the corrective action

program as problem evaluation report (PER) 772193 and performed repairs to the valve

to restore the system to operable status.

This finding was determined to be more than minor because it was associated with the

Design Control attribute of the Mitigating Systems cornerstone and adversely affected

the cornerstones objective to ensure the availability, reliability, and capability of systems

that respond to initiating events to prevent undesirable consequences (i.e., core

damage). Specifically, the finding reduced the reliability and capability of the A train

RHR system to perform its safety function as designed. The finding required a detailed

risk analysis as the A RHR system was inoperable beyond its allowed outage time of 72

hours. The detailed risk analysis concluded that the finding was of very low safety

significance (Green). This finding was determined to have a cross-cutting aspect

relating to the proper classification, prioritization, and evaluation of operability and

reportability of conditions adverse to quality in the Corrective Action component of the

Problem Identification and Resolution area. P.1(c) (Section 4OA5)

B. Licensee-Identified Violations

None

Enclosure

REPORT DETAILS

Summary of Plant Status:

Unit 1 operated at or near 100 percent rated thermal power (RTP) until September 9, 2013,

when the unit entered a power coast down period until October 14 when the unit shut down for a

refueling outage. Unit 1 returned to 100 percent RTP on November 24 where it operated for the

remainder of the inspection period.

Unit 2 operated at or near 100 percent RTP for the entire inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

.1 Readiness for Seasonal Extreme Weather Conditions

The inspectors reviewed design features and licensee preparations for protecting the

essential raw cooling water (ERCW) intake structure and both Unit 1 and 2 refueling

water storage tanks (RWSTs) from extreme cold and freezing conditions. The

inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and Technical

Specifications (TS), reviewed implementation of licensee freeze protection procedures,

walked down portions of the systems to assess deficiencies and system readiness for

extreme cold weather, and discussed prioritization and status of correcting deficiencies

with licensee personnel. Documents reviewed are listed in the Attachment. The

inspectors completed one sample.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdown

a. Inspection Scope

The inspectors performed partial walkdowns of the following three systems to verify the

operability of redundant or diverse trains and components when safety equipment was

inoperable. The inspectors focused on identification of discrepancies that could impact

the function of the system and, therefore, potentially increase risk. The inspectors

reviewed applicable operating procedures, walked down control system components,

and determined whether selected breakers, valves, and support equipment were in the

correct position to support system operation. The inspectors also verified that the

licensee had properly identified and resolved equipment alignment problems that could

Enclosure

4

cause initiating events or impact the capability of mitigating systems or barriers and

entered them into the corrective action program (CAP). Documents reviewed are listed

in the Attachment. The inspectors completed 3 samples.

• Spent fuel pool cooling during core empty period of U1R19

• 1A emergency core cooling train while 1B 669 penetration cooler out-of-service

• 2A auxiliary feed-water and 2A emergency diesel generator while 2B under-voltage

coils out-of-service

.2 Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of the: 1) emergency gas

treatment system/auxiliary building gas treatment system (ABGTS); and 2) auxiliary

building ventilation/control building ventilation systems. The purpose of this inspection

was to verify proper equipment alignment, to identify any discrepancies that could impact

the function of the system and increase risk, and to verify that the licensee properly

identified and resolved equipment alignment problems that could cause events or impact

the functional capability of the system.

The inspectors reviewed the UFSAR, system procedures, system drawings, and system

design documents to determine the correct lineup and then examined system

components and their configuration to identify any discrepancies between the existing

system equipment lineup and the correct lineup. During the walkdown, the inspectors

reviewed the following:

• Dampers were correctly positioned.

• Electrical power was available as required.

• Hangers and supports were correctly installed and functional.

• Essential support systems were operational.

• Ancillary equipment or debris did not interfere with system performance.

• Breakers were correctly positioned.

• Major system components were correctly labeled.

• Cabinets, cable trays, and conduits were correctly installed and functional.

• Visible cabling appeared to be in good material condition.

In addition, the inspectors reviewed corrective action items and design issues associated

with the systems to determine whether any condition described in those documents

could adversely impact current system operability. Documents reviewed are listed in the

Attachment. The inspectors completed two samples.

b. Findings

No findings were identified.

Enclosure

5

1R05 Fire Protection

.1 Fire Protection Tours

a. Inspection Scope

The inspectors conducted a tour of the six areas important to safety listed below to

assess the material condition and operational status of fire protection features. The

inspectors evaluated whether: combustibles and ignition sources were controlled in

accordance with the licensees administrative procedures; fire detection and suppression

equipment was available for use; passive fire barriers were maintained in good material

condition; and compensatory measures for out-of-service, degraded, or inoperable fire

protection equipment were implemented in accordance with the licensees fire plan.

Documents reviewed are listed in the Attachment. The inspectors completed six

samples.

• Unit 1 Lower Containment Building

• Unit 1 Upper Containment Building

• Control Building Elevation 685 (Auxiliary Instrument Room)

• Control Building Elevation 706 (Cable Spreading Room)

• ERCW Building - Elevations 688/704/720

• Turbine Building - Elevations 662/685

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.1 Internal Flooding

a. Inspection Scope

The inspectors examined internal flood protection measures associated with the 1A and

1B safety injection (SI) pump rooms internal flood design in order to verify that flood

mitigation plans were consistent with the design requirements and risk analysis

assumptions. The inspectors verified that equipment essential for reactor shutdown was

properly protected from a flood caused by pipe breaks in the 1A & 1B SI pump room.

Specifically, the inspectors reviewed the licensees moderate energy line break flooding

study to fully understand the licensees flood mitigation strategy, reviewed licensee

drawings and then verified that the assumptions and results remained valid. The

inspectors walked down the 1A & 1B SI pump room to verify the assumed flooding

sources, adequacy of common area drainage, and flood detection instrumentation to

ensure that a flooding event would not impact reactor shutdown capabilities. The

inspectors completed one sample.

Enclosure

6

b. Findings

No findings were identified.

1R08 Non-Destructive Examination Activities and Welding Activities

a. Inspection Scope

From October 21-25, 2013, the inspectors conducted an on-site review of the

implementation of the licensees in-service inspection (ISI) Program for monitoring

degradation of the reactor coolant system; emergency feedwater systems, risk-

significant piping and components, and containment systems in Unit 1.

The inspectors activities included a review of non-destructive examinations (NDEs) to

evaluate compliance with the applicable edition of the American Society of Mechanical

Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, and to verify that

indications and defects were appropriately evaluated and dispositioned in accordance

with the requirements of the ASME Code,Section XI, acceptance standards or NRC

approved alternative requirement.

The inspectors directly observed or reviewed records of the following NDEs mandated

by the ASME Code to evaluate compliance with the ASME Code Section XI and Section

V requirements, and if any indications and defects were detected. Inspectors also

reviewed evaluations of results that were dispositioned in accordance with the ASME

Code or an NRC-approved alternative requirement.

• Directly observed:

o Ultrasonic testing (UT) examinations of the reactor pressure vessel head to shell

flange studs

o General visual examination of the outside surface of the containment shell

• Reviewed records:

o UT examinations of reactor coolant pump #4 bolting

o VT-3 visual examination of containment penetration bolting

o Work Order 113312025 modification of component cooling water system piping

The inspectors reviewed documentation for the repair/replacement of the following

pressure boundary welds. The inspectors evaluated if the licensee applied the pre-

service non-destructive examinations and acceptance criteria required by the

Construction Code. In addition, the inspectors reviewed the welding procedure

specifications, welder qualifications, welding material certifications, and supporting weld

procedure qualification records to evaluate if the weld procedures were qualified in

accordance with the requirements of the Construction Code and the ASME Code

Section XI.

Enclosure

7

PWR Vessel Upper Head Penetration (VUHP) Inspection Activities: For the Unit 1

vessel head, a bare metal visual examination and a volumetric examination required in

accordance with the requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D) were conducted in the previous outage and therefore not required to

be performed this outage.

Boric Acid Corrosion Control (BACC) Inspection Activities: The inspectors reviewed the

licensees BACC program activities to ensure implementation with commitments made in

response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor

Pressure Boundary, and applicable industry guidance documents. Specifically, the

inspectors performed an on-site record review of procedures and the results of the

licensees containment walkdown inspections performed during the current refueling

outage. The inspectors also reviewed Focused Self-Assessment CRP-ENG-F-13-031 of

the Boric Acid Program.

The inspectors also interviewed the BACC program owner, conducted an independent

walkdown of containment to evaluate compliance with licensees BACC program

requirements, and verified that degraded or non-conforming conditions, such as boric

acid leaks, were properly identified and corrected in accordance with the licensees

BACC and corrective action programs.

The inspectors reviewed the following evaluations and corrective actions related to

evidence of boric acid leakage to evaluate if the corrective actions completed were

consistent with the requirements of the ASME Code Section XI and 10 CFR Part 50,

Appendix B, Criterion XVI.

• Problem Event Report (PER) 618770 - Boron buildup on 1B-B SI pump pedestal

• PER 691545 - Boric acid build up and wet boric acid are present on transmitter

sensing line 1-FT-72-41

Steam Generator (SG) Tube Inspection Activities:

There were no SG tube eddy current examinations conducted during this outage. The

inspectors reviewed the following documentation and evaluated them against the

licensees TS, commitments made to the NRC, ASME Section XI, and Nuclear Energy

Institute (NEI) 97-06, Steam Generator Program Guidelines, to ensure that the licensee

was in compliance with the schedule to skip the SG eddy current testing inspections for

the 1R19 outage:

• AREVA document # 51-9178898-001, Sequoyah Unit Condition Monitoring for Cycle

18 and Operational Assessment for Cycles 19, 20 and 21

Identification and Resolution of Problems:

The inspectors performed a review of selected ISI-related problems that were identified

by the licensee and entered into the corrective action program as PERs. The inspectors

reviewed the PERs to confirm the licensee had appropriately described the scope of the

problem and had initiated corrective actions. The review also included the licensees

Enclosure

8

consideration and assessment of operating experience events applicable to the plant.

The inspectors performed this review to ensure compliance with 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, requirements. Documents reviewed are

listed in the Attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

The inspectors performed one licensed operator requalification program review. The

inspectors observed a simulator session on October 9, 2013. The training scenario

involved Just-In-Time Training for Pre-Refueling Outage risk significant activities such as

placing the RHR system in service. The inspectors observed crew performance in terms

of communications; ability to take timely and proper actions; prioritizing, interpreting, and

verifying alarms; correct use and implementation of procedures, including the alarm

response procedures; timely control board operation and manipulation, including high

risk operator actions; oversight and direction provided by shift manager, including the

ability to identify and implement appropriate TS action; and, group dynamics involved in

crew performance. The inspectors also observed the evaluators critique and reviewed

simulator fidelity to verify that it matched actual plant response. Documents reviewed

are listed in the Attachment. The inspectors completed one sample.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed and assessed licensed operator performance in the main

control room during periods of heightened activity or risk. The inspectors reviewed

various licensee policies and procedures such as OPDP-1, Conduct of Operations,

NPG-SPP-10.0, Plant Operations, and 0-GO-5, Normal Power Operation. The

inspectors utilized activities such as post-maintenance testing, surveillance testing,

unplanned transients, infrequent plant evolutions, plant startups and shutdowns, reactor

power and turbine load changes, and refueling and other outage activities to focus on

the following conduct of operations as appropriate:

• operator compliance and use of procedures

• control board manipulations

• communication between crew members

Enclosure

9

• use and interpretation of plant instruments, indications, and alarms

• use of human error prevention techniques

• documentation of activities, including initials and sign-offs in procedures

• supervision of activities, including risk and reactivity management

• pre-job briefs

Specifically, the inspectors observed licensed operator performance during the following

activities:

• Unit 1 reactor shutdown and plant cool down/depressurization

• Unit 1 refueling and other outage activities

• Unit 1 startup, including Mode changes

• Unit 2 down power with turbine in manual for valve testing

Documents reviewed are listed in the Attachment. The inspectors completed one

sample.

b. Findings

No findings were identified.

.3 Annual Review of Licensee Requalification Examination Results

a. Inspection Scope

On September 13, 2013, the licensee completed the annual requalification operating

examinations required to be administered to all licensed operators in accordance with 10

CFR 55.59(a)(2), Requalification requirements, of the NRCs Operators Licenses.

The inspectors performed an in-office review of the overall pass/fail results of the

individual operating examinations and the crew simulator operating examinations in

accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification

Program and Licensed Operator Performance. The results were compared to the

thresholds established in Section 3.02, Requalification Examination Results, of IP

71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed five maintenance activities, issues, and/or systems listed below

to verify the effectiveness of the licensees activities in terms of: appropriate work

practices; identifying and addressing common cause failures; scoping in accordance

with 10 CFR 50.65(b); characterizing reliability issues for performance; trending key

Enclosure

10

parameters for condition monitoring; charging unavailability for performance;

classification in accordance with 10 CFR 50.65(a)(1) or (a)(2); appropriateness of

performance criteria for structures, systems, or components (SSCs) and functions

classified as (a)(2); and appropriateness of goals and corrective actions for SSCs and

functions classified as (a)(1). Documents reviewed are listed in the Attachment. The

inspectors completed 5 samples.

• MR 11th Periodic Assessment Report (PE sample)

• Cause Determination and Evaluation (CDE) #2700, FCV-63-72 Failure

• CDE #2696, EBGTS B Fan Failure

• CDE #2686, A Shutdown Boardroom Chiller Failure

• CDE #2674, B Main Condenser Test Connection Failure

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the following activities to determine whether appropriate risk

assessments were performed prior to removing equipment from service for

maintenance. The inspectors evaluated whether risk assessments were performed as

required by 10 CFR 50.65(a)(4), and were accurate and complete. When emergent

work was performed, the inspectors reviewed whether plant risk was promptly

reassessed and managed. The inspectors also assessed whether the licensees risk

assessment tool use and risk categories were in accordance with Standard Programs

and Processes Procedure NPG-SPP-07.1, On-Line Work Management, Revision 3,

and Instruction 0-TI-DSM-000-007.1, Risk Assessment Guidelines, Revision 9.

Documents reviewed are listed in the Attachment. The inspectors completed 2 samples.

• Review U1R19 Outage Schedule

• Review of risk during ABGTS outage

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

For the eight operability evaluations described in the PERs listed below, the inspectors

evaluated the technical adequacy of the evaluations to ensure that TS operability was

properly justified and the subject component or system remained available, such that no

unrecognized increase in risk occurred. The inspectors compared the operability

Enclosure

11

evaluations to UFSAR descriptions to determine if the system or components intended

function(s) were adversely impacted. In addition, the inspectors reviewed compensatory

measures implemented to determine whether the compensatory measures worked as

stated and the measures were adequately controlled. The inspectors also reviewed a

sampling of PERs to assess whether the licensee was identifying and correcting any

deficiencies associated with operability evaluations. Documents reviewed are listed in

the Attachment. The inspectors completed 8 samples.

• PER 789552 - Unit 2 Turbine Controls in Manual

• PER 795451 - POE WO 113223153 T1 motor lead pinch

• PER 799097 - POE TS LCO 3.7.4 action for FCV-67-146

• PER 800432 - POE (ABSCE boundary issue)

• PER 795433 - PDO (During U1R19 water found leaking out of conduit in bioshield

wall)

• PER 801415 - PDO EDG 1B 2 sec load sequence

• PER 803833 - PDO U-1 Rx Head Vent Valve Stroke

• PERs 816731, 815638, 817841 - FEs associated with the Unit 1 loose parts alarm

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

The inspectors reviewed the modification listed below and the associated 10 CFR 50.59

screening, and compared it against the UFSAR and TS to verify whether the

modification affected operability or availability of the affected system.

• DCN 22643 - Replace Pressurizer Power Operated Relief Valves (PORVs)

Following installation and testing, the inspectors observed indications affected by the

modification, discussed them with operators, and verified that the modification was

installed properly and its operation did not adversely affect safety system functions. The

inspectors did note that, ultimately, the installed PORVs did not meet the acceptance

criteria associated with the close stroke time. As a result, the licensee chose to cut

out/remove the new style PORVs and reinstall the original PORVs prior to plant startup

in November 2013. Documents reviewed are listed in the Attachment. The inspectors

completed one sample.

b. Findings

No findings were identified.

Enclosure

12

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post maintenance tests associated with the nine work

orders (WO) listed below to assess whether procedures and test activities ensured

system operability and functional capability. The inspectors reviewed the licensees test

procedure to evaluate whether: the procedure adequately tested the safety function(s)

that may have been affected by the maintenance activity; the acceptance criteria in the

procedure were consistent with information in the applicable licensing basis and/or

design basis documents; and the procedure had been properly reviewed and approved.

The inspectors also witnessed the test or reviewed the test data to determine whether

test results adequately demonstrated restoration of the affected safety function(s).

Documents reviewed are listed in the Attachment. The inspectors completed nine

samples.

• WO 113377829 - Repack Valve (1-LCV-3-175) and perform AIRCET test

• WO 112096045 - Repair isolation check valve (1-VLV-026-1296)

• WO 111234712 - 5 year PM to swap 480V Shutdown board breaker with a

refurbished breaker

• WO 113806636 - Perform 0-MI-EPM-317-102.0 on CCS pump C-S and

clean/replace motor air filter

• WO 114560807 - Centrifugal charging pump (CCP) room cooler fan motor current

check, bearing lubrication and cleaning

• WO 114198329 - EQ maintenance and inspection

• WO 113408190 - Change out electrolytic capacitors in the Woodward 2301A

governor card

• WOs 114306842, 114306841, 114325805, 114325799 - Aux Feedwater valves -

836 & 837

• WO 113756597 - PORVs - PCV-68-340 & PCV-68-334

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

.1 Unit 1 Refueling Outage Cycle 19

a. Inspection Scope

For the Unit 1 refueling outage that began on October 14, 2013, the inspectors

evaluated licensee activities to verify that the licensee considered risk in developing

outage schedules, followed risk reduction methods developed to control plant

configuration, developed mitigation strategies for the loss of key safety functions, and

adhered to operating license and TS requirements that ensure defense-in-depth. The

inspectors also walked down portions of Unit 1 not normally accessible during at-power

Enclosure

13

operations to verify that safety-related and risk-significant SSCs were maintained in an

operable condition. Specifically, between October 14 and November 21, the inspectors

performed inspections and reviews of the following outage activities. Documents

reviewed are listed in the Attachment. The inspectors completed one sample.

• Outage Plan. The inspectors reviewed the outage safety plan and contingency plans

to confirm that the licensee had appropriately considered risk, industry experience,

and previous site-specific problems in developing and implementing a plan that

assured maintenance of defense-in-depth.

• Reactor Shutdown. The inspectors observed the shutdown in the control room from

the time the reactor was tripped until operators placed it on the RHR system for

decay heat removal to verify that TS cool down restrictions were followed. The

inspectors also toured the lower containment as soon as practicable after reactor

shutdown to observe the general condition of the reactor coolant system (RCS) and

emergency core cooling system components and to look for indications of previously

unidentified leakage inside the polar crane wall.

• Licensee Control of Outage Activities. On a daily basis, the inspectors attended the

licensee outage turnover meeting, reviewed PERs, and reviewed the defense-in-

depth status sheets to verify that status control was commensurate with the outage

safety plan and in compliance with the applicable TS when taking equipment out of

service. The inspectors further toured the main control room and areas of the plant

daily to ensure that the following key safety functions were maintained in accordance

with the outage safety plan and TS: electrical power, decay heat removal, spent fuel

cooling, inventory control, reactivity control, and containment closure. The

inspectors also observed a tag-out of the B Train CCP system to verify that the

equipment was appropriately configured to safely support the work and testing. To

ensure that RCS level instrumentation was properly installed and configured to give

accurate information, the inspectors reviewed the installation of the Mansell level

monitoring system. Specifically, the inspectors discussed the system with

engineering, walked it down to verify that it was installed in accordance with

procedures and adequately protected from inadvertent damage, verified that Mansell

indication properly overlapped with pressurizer level instruments during pressurizer

drain-down, verified that operators properly set level alarms to procedurally required

set-points, and verified that the system consistently tracked RCS level while lowering

to reduced inventory conditions. The inspectors also observed operators compare

the Mansell indications with locally-installed ultrasonic level indicators during entry

into reduced inventory conditions.

Enclosure

14

• Refueling Activities. The inspectors observed fuel movement at the spent fuel pool

and at the refueling cavity in order to verify compliance with TS and that each

assembly was properly tracked from core offload to core reload. In order to verify

proper licensee control of foreign material, the inspectors verified that personnel

were properly checked before entering any foreign material exclusion (FME) areas,

reviewed FME procedures, and verified that the licensee followed the procedures.

To ensure that fuel assemblies were loaded in the core locations specified by the

design, the inspectors independently reviewed the recording of the licensees final

core verification.

• Reduced Inventory and Mid-Loop Conditions. Prior to the outage, the inspectors

reviewed the licensees commitments to Generic Letter 88-17. Before entering

reduced inventory conditions the inspectors verified that these commitments were in

place, that plant configuration was in accordance with those commitments, and that

distractions from unexpected conditions or emergent work did not affect operator

ability to maintain the required reactor vessel level. Mid-loop conditions were not

entered during this outage since SG eddy current testing was not required.

• Heat-up and Start-up Activities. The inspectors toured the containment prior to

reactor startup to verify that debris that could affect the performance of the

containment sump had not been left in the containment. The inspectors reviewed

the licensees mode-change checklists to verify that appropriate prerequisites were

met prior to changing TS modes. To verify RCS integrity and containment integrity,

the inspectors further reviewed the licensees RCS leakage calculations and

containment isolation valve lineups. In order to verify that core operating limit

parameters were consistent with core design, the inspectors also examined portions

of the low power physics testing surveillance.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the twelve surveillance tests identified below, the inspectors assessed whether the

SSCs involved in these tests satisfied the requirements described in the TS surveillance

requirements, the UFSAR, applicable licensee procedures, and whether the tests

demonstrated that the SSCs were capable of performing their intended safety functions.

This was accomplished by witnessing testing and/or reviewing the test data. Documents

reviewed are listed in the Attachment. The inspectors completed twelve samples.

Enclosure

15

In-Service Tests:

• 1-SI-SXP-003-202.B, Motor Driven Auxiliary Feedwater Pump 1B-B Comprehensive

Performance Test, Revision 7

• 1-SI-SXP-074-202.0, RHR Pump 1A-A and 1B-B Comprehensive Performance and

Check Valve Test, Revision 10

RCS leakage test:

• 0-SI-OPS-068-137.0, Reactor Coolant System Water Inventory, Revision 32

Routine Surveillance Tests:

• 1-SI-OPS-088-001.0, Phase A Isolation Test, Revision 14

• 1-SI-OPS-082-026A, Loss of Offsite Power with Safety Injection D/G 1A-A Test,

Revision 46

• 0-SI-SFT-072-138.0, Unit 1 Containment Spray - Spray Nozzle Test, Revision 6

• 0-SI-SXV-063-203.2, Full Stroking of Safety Injection Cold Leg Accumulator Isolation

Valves, Revision 1

Ice Condenser Surveillance Test:

• 0-SI-MIN-061-105.0, Ice Condenser Ice Weighing, Revision 11

Containment Isolation Valve (CIV) Surveillance Tests:

• 0-SI-SLT-067-258.2, Containment Isolation Valve Local Leak Rate Test Lower

Compartment Essential Raw Cooling Water, Revision 13

• 0-SI-SLT-088-259.4, Upper Personnel Airlock Interlock Operability Test, Revision 2

• 0-SI-SLT-088-259.1, Upper Personnel Airlock Overall Leak Rate Test and General

Inspection, Revision 6

• 0-SI-SLT-081-258.1, Containment Isolation Valve Local Leak Rate Test Primary

Water System, Revision 5

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors evaluated the adequacy of the licensees methods for testing and

maintaining the alert and notification system in accordance with NRC Inspection

Procedure 71114, Attachment 02, Alert and Notification System Evaluation. The

Enclosure

16

applicable planning standard, 10 CFR Part 50.47(b)(5) and its related 10 CFR Part 50,

Appendix E,Section IV.D requirements were used as reference criteria. The criteria

contained in NUREG-0654, Criteria for Preparation and Evaluation of Radiological

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,

Revision 1, were also used as a reference.

The inspectors reviewed various documents which are listed in the Attachment,

interviewed personnel responsible for system performance, and observed aspects of

periodic siren maintenance and testing. This inspection activity satisfied one inspection

sample for the alert and notification system on a biennial basis.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System

a. Inspection Scope

The inspectors reviewed the licensees Emergency Response Organization (ERO)

augmentation staffing requirements and process for notifying the ERO to ensure the

readiness of key staff for responding to an event and timely facility activation. The

qualification records of key position ERO personnel were reviewed to ensure all ERO

qualifications were current. A sample of problems identified from augmentation drills or

system tests performed since the last inspection was reviewed to assess the

effectiveness of corrective actions.

The inspection was conducted in accordance with NRC Inspection Procedure 71114,

Attachment 03, Emergency Response Organization Staffing and Augmentation System.

The applicable planning standard, 10 CFR 50.47(b)(2), and its related 10 CFR 50,

Appendix E requirements were used as reference criteria.

The inspectors reviewed various documents which are listed in the Attachment. This

inspection activity satisfied one inspection sample for the ERO staffing and

augmentation system on a biennial basis.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The NRC Office of Nuclear Security and Incident Response headquarters staff

performed an in-office review of the latest revisions of various Emergency Plan

Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS

Enclosure

17

Accession numbers ML12326A678, ML12353A050, ML13025A102, ML13070A025,

ML13219A022, and ML13246A091.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in

the revisions resulted in no reduction in the effectiveness of the Plan, and that the

revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to

10 CFR Part 50. The NRC review was not documented in a safety evaluation report and

did not constitute approval of licensee-generated changes; therefore, these revisions are

subject to future inspection. Documents reviewed are listed in the Attachment. The

inspectors completed one sample.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspectors reviewed the corrective actions identified through the Emergency

Preparedness program to determine the significance of the issues, the completeness

and effectiveness of corrective actions, and to determine if issues were recurring. The

licensees post-event after action reports, self-assessments, and audits were reviewed to

assess the licensees ability to be self-critical, thus avoiding complacency and

degradation of their emergency preparedness program. Inspectors reviewed the

licensees 10 CFR 50.54(q) change process, personnel training, and selected

screenings and evaluations to assess adequacy. The inspectors toured facilities and

reviewed equipment and facility maintenance records to assess licensees adequacy in

maintaining them. The inspectors evaluated the capabilities of selected radiation

monitoring instrumentation to adequately support Emergency Action Level (EAL)

declarations.

The inspection was conducted in accordance with NRC Inspection Procedure 71114.05,

Maintenance of Emergency Preparedness. The applicable planning standards, related

10 CFR 50, Appendix E requirements, and 10 CFR 50.54(q) and (t) were used as

reference criteria.

The inspectors reviewed various documents which are listed in the Attachment. This

inspection activity satisfied one inspection sample for the maintenance of emergency

preparedness on a biennial basis.

b. Findings

No findings were identified.

Enclosure

18

2. RADIATION SAFETY (RS)

Cornerstones: Occupational Radiation Safety (OS) and Public Radiation Safety (PS)

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

Hazard Assessment and Instructions to Workers: During facility tours, the inspectors

directly observed labeling of radioactive material and postings for radiation areas, high

radiation areas (HRAs), and airborne radioactivity areas established within the

radiologically controlled area (RCA) of the Unit 1 containment, Unit 1 and Unit 2 auxiliary

buildings, Independent Spent Fuel Storage Installation (ISFSI), and radioactive waste

(radwaste) processing and storage locations. The inspectors independently measured

radiation dose rates or directly observed conduct of licensee radiation surveys for RCA

areas in the Unit 1 containment, Unit 1 and Unit 2 Auxiliary buildings, and ISFSI. The

inspectors reviewed survey records for several plant areas including surveys for alpha

emitters, airborne radioactivity, and pre-job surveys for selected Unit 1 Refueling Outage

19 (U1R19) tasks. The inspectors also discussed changes to plant operations that could

contribute to changing radiological conditions since the last inspection and reviewed

U1R19 crud burst results and post crud burst dose rate surveys. For selected U1R19

outage jobs, the inspectors attended, or reviewed, pre-job briefings and radiation work

permit (RWP) details to assess communication of radiological control requirements and

current radiological conditions to workers. Selected U1R19 work activities included Unit

1 control rod drive mechanism duct work, Unit 1 Refueling Activities, Unit 1 Head O-ring

Surface Work & Inspection, and work in the Unit 1 Equipment Pit and transfer canal.

Hazard Control and Work Practices: The inspectors evaluated access barrier

effectiveness for selected Unit 1 and Unit 2 Locked High Radiation Area (LHRA) and

Very High Radiation Area (VHRA) locations. Changes to procedural guidance for LHRA

and VHRA controls were discussed with health physics (HP) supervisors. Controls and

their implementation for storage of irradiated material within the spent fuel pool (SFP)

were reviewed and discussed in detail. Established radiological controls (including

airborne controls) were evaluated for selected U1R19 tasks including refueling and

reactor cavity work activities, work in auxiliary building HRAs, and radwaste processing

and storage. In addition, licensee controls for areas where dose rates could change

significantly as a result of plant shutdown and refueling operations were reviewed and

discussed.

Occupational workers adherence to selected RWPs and HP technician (HPT)

proficiency in providing job coverage were evaluated through direct observations and

interviews with licensee staff. Electronic dosimeter (ED) alarm set points and worker

stay times were evaluated against area radiation survey results for refueling and reactor

cavity work. ED alarm logs were reviewed and worker response to dose and dose rate

alarms during selected work activities was evaluated. For HRA tasks involving

significant dose rate gradients, e.g. reactor head O-ring work, the inspectors evaluated

the use and placement of whole body and extremity dosimetry to monitor worker

exposure.

Enclosure

19

Control of Radioactive Material: The inspectors observed surveys of material and

personnel being released from the RCA using small article monitor, personnel

contamination monitor, and portal monitor instruments. The inspectors reviewed the last

two calibration records for selected release point survey instruments and discussed

equipment sensitivity, alarm set points, and release program guidance with licensee

staff. The inspectors compared recent 10 CFR Part 61 results for the Dry Active Waste

(DAW) radioactive waste stream with radionuclides used in calibration sources to

evaluate the appropriateness and accuracy of release survey instrumentation. The

inspectors also reviewed records of leak tests on selected sealed sources and discussed

nationally tracked source transactions with licensee staff.

Problem Identification and Resolution: PERs associated with radiological hazard

assessment and control were reviewed and assessed. The inspectors evaluated the

licensees ability to identify and resolve the issues in accordance with procedure NPG-

SPP-22.300, Corrective Action Program, Rev. 0. The inspectors also evaluated the

scope of the licensees internal audit program and reviewed recent assessment results.

Radiation protection activities were evaluated against the requirements of UFSAR

Section 12; TS Sections 6.8 and 6.12; 10 CFR Parts 19 and 20; and approved licensee

procedures. Licensee programs for monitoring materials and personnel released from

the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of

Radioactively Contaminated Material. Documents reviewed are listed in the

Attachment. The inspectors completed one sample.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation

a. Inspection Scope

Waste Processing and Characterization: During inspector walkdowns, accessible

sections of the liquid and solid radwaste processing systems were assessed for material

condition and conformance with system design diagrams. Inspected equipment included

radwaste storage tanks; resin transfer piping, resin, and filter packaging components;

and abandoned boric acid evaporator equipment. The inspectors discussed component

function, processing system changes, and radwaste program implementation with

licensee staff.

The radionuclide characterizations for 2010, and 2012, for selected waste streams were

reviewed and discussed with Radwaste/Transportation staff. For primary resin, reactor

coolant system filters, and DAW, the inspectors evaluated analyses for hard-to-detect

nuclides, reviewed the use of scaling factors, and examined quality assurance

comparison results between licensee waste stream characterizations and outside

laboratory data. Waste stream mixing and concentration averaging methodology for

resins and filters was evaluated and discussed with Radwaste/Transportation staff. The

Enclosure

20

inspectors also reviewed the licensees procedural guidance for monitoring changes in

waste stream isotopic mixtures. The 10 CFR 61 analysis results were also discussed

with Chemistry personnel.

Radioactive Material Storage: During walkdowns of indoor and outdoor radioactive

material storage areas, the inspectors observed the physical condition and labeling of

storage containers and the posting of Radioactive Material Areas. The inspectors also

reviewed licensee procedural guidance for storage and monitoring of radioactive

material.

Transportation: The inspectors observed a shipment of vendor equipment during the

week of inspection. The inspectors reviewed shipping procedure requirements and

discussed preparation of shipping documents, package marking and labeling, and

interviewed shipping technicians regarding Department of Transportation (DOT)

regulations.

Selected shipping records were reviewed for consistency with licensee procedures and

compliance with NRC and DOT regulations. The inspectors reviewed emergency

response information, DOT shipping package classification, waste classification,

radiation survey results, and evaluated whether receiving licensees were authorized to

accept the packages. Licensee procedures for handling shipping containers were

compared to Certificate of Compliance requirements and manufacturer

recommendations. In addition, training records for selected individuals currently

qualified to ship radioactive material were reviewed.

Radwaste processing activities and equipment configuration were reviewed for

compliance with the licensees Process Control Program and UFSAR, Chapter 11.

Waste stream characterization analyses were reviewed against regulations detailed in

10 CFR Part 20, 10 CFR Part 61, and guidance provided in the Branch Technical

Position on Waste Classification (1983). Radioactive material and waste storage

activities were reviewed against the requirements of 10 CFR Part 20. Transportation

program implementation was reviewed against regulations detailed in 10 CFR Part 20,

10 CFR Part 71, 49 CFR Parts 172-178, as well as the guidance provided in NUREG-

1608. Training activities were assessed against 49 CFR Part 172, Subpart H.

Problem Identification and Resolution: The inspectors reviewed PERs in the area of

radwaste processing and transportation. The inspectors evaluated the licensees ability

to identify and resolve the issues in accordance with procedure NPG-SPP-22.300,. The

inspectors also evaluated the scope of the licensees internal audit program and

reviewed recent assessment results. Documents reviewed are listed in the Attachment.

The inspectors completed one sample.

b. Findings

No findings were identified.

Enclosure

21

4. OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

Occupational Radiation Safety Cornerstone: The inspectors reviewed the Occupational

Exposure Control Effectiveness PI results for the Occupational Radiation Safety

Cornerstone from October 2012 through October 2013. For the assessment period, the

inspectors reviewed ED alarm logs and selected PERs related to controls for exposure

significant areas. The inspectors also reviewed licensee procedural guidance for

collecting and documenting PI data. Documents reviewed are listed in the Attachment.

The inspectors completed one sample.

Emergency Preparedness Cornerstone:

• Drill/Exercise Performance (DEP)

• Emergency Response Organization Drill Participation (ERO)

• Alert and Notification System Reliability (ANS)

For the specified review period, the inspectors examined data reported to the NRC,

procedural guidance for reporting PI information, and records used by the licensee to

identify potential PI occurrences. The inspectors verified the accuracy of the PI for ERO

drill and exercise performance through review of a sample of drill and event records.

The inspectors reviewed selected training records to verify the accuracy of the PI for

ERO drill participation for personnel assigned to key positions in the ERO. The

inspectors verified the accuracy of the PI for alert and notification system reliability

through review of a sample of the licensees records of periodic system tests. The

inspectors also interviewed the licensee personnel who were responsible for collecting

and evaluating the PI data. Documents reviewed are listed in the Attachment. This

inspection satisfied three inspection samples for PI verification on an annual basis.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

As required by IP 71152, Problem Identification and Resolution, and in order to help

identify repetitive equipment failures or specific human performance issues for follow-up,

the inspectors performed a daily screening of items entered into the licensees CAP.

This was accomplished by reviewing the description of each new PER and attending

daily management review committee meetings.

Enclosure

22

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors performed an in-depth review of PER 665633, NRC identified freeze

protection issues. The inspectors reviewed the actions taken to determine if the

licensee had adequately addressed the following attributes. Documents reviewed are

listed in the Attachment. The inspectors completed one sample for Annual Follow-up of

Selected Issues.

• Complete, accurate and timely identification of the problem

• Evaluation and disposition of operability and reportability issues

• Consideration of previous failures, extent of condition, generic or common cause

implications

• Prioritization and resolution of the issue commensurate with safety significance

• Identification of the root cause and contributing causes of the problem

• Identification and implementation of corrective actions commensurate with the safety

significance of the issue

b. Findings

No findings were identified.

.3 Semiannual Trend Review

a. Inspection Scope

As required by IP 71152, the inspectors performed a review of the licensees corrective

action program and associated documents to identify trends that could indicate the

existence of a more significant safety issue. The inspectors review was focused on

repetitive equipment issues, but also included licensee trending efforts and licensee

human performance results. The inspectors review nominally considered the twelve-

month period of January 2013 through December 2013, although some examples

expanded beyond those dates when the scope of the trend warranted. Specifically, the

inspectors considered the results of daily inspector screening discussed in Section

4OA2.1 and reviewed licensee trend reports for the period in order to determine the

existence of any adverse trends that the licensee may not have previously identified.

Documents reviewed are listed in the Attachment. The inspectors completed one

sample for Semiannual Trend Review.

b. Findings and Observations

No findings were identified. In general, the licensee had identified trends and

Enclosure

23

appropriately addressed them in their CAP. The inspectors evaluated the licensee

trending methodology and observed that the licensee had performed a detailed review.

The licensee routinely reviewed cause codes, involved organizations, key words, and

system links to identify potential trends in their data. The inspectors compared the

licensee process results with the results of the inspectors daily screening. No

previously unidentified trends of significance were identified.

.4 Annual Follow-up of Operator Workarounds

a. Inspection Scope

The inspectors reviewed the operator workaround (OWA) program to verify that OWAs

were identified at an appropriate threshold, were entered into the CAP, and that

corrective actions were appropriate and timely. Specifically, the inspectors reviewed the

licensees workaround lists and repair schedules, reviewed CAP word searches,

conducted tours and interviewed operators and operations department support staff.

Additionally, the inspectors checked for undocumented workarounds by observing

operators perform rounds, reviewed operator deficiency lists, reviewed appropriate

system health documents, attended plant health committee meetings, and verified that

identified program deficiencies were corrected. The inspectors evaluated all

workarounds for their aggregate impact. Documents reviewed are listed in the

Attachment. The inspectors completed one sample for Annual Follow-up of Operator

Workarounds.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Closed) Unresolved Item (URI) 050000327/2013004-01, Water Intrusion into Actuator of

Valve 1-FCV-63-72

a. Inspection Scope

The inspectors opened this URI as a result of water intrusion into the actuator of 1-FCV-

63-72, which is the A train containment sump suction for the Unit 1 A RHR train. This

issue was noted during an operability inspection conducted last quarter. The inspectors

determined more inspection was required in order to resolve the issue. On August 8,

2013, an operator noted the valve exhibited dual indication and on August 14, a related

valve, 1-FCV-74-3, failed its periodic stroke test. The following day, 1-FCV-63-72 was

noted to be failed as well due to a large of amount of water buildup in the actuator. A

subsequent root cause of the failure was completed during this inspection period and

concluded the water intrusion was due to groundwater which migrated through the wall

of the RHR valve vault room and into the valve conduit. Although the circumstances

regarding the water intrusion may have been beyond the licensees ability to predict, the

Enclosure

24

inspectors noted there were opportunities before August 14 to identify and correct the

deficient condition. Thus, the inspectors identified the following non-cited violation

(NCV) as discussed below. Documents reviewed are listed in the Attachment.

b. Findings

Introduction: A self-revealing Green NCV of 10 CFR 50 Appendix B, Criterion XVI,

Corrective Action, was identified for the licensees failure to correct a condition adverse

to quality within a reasonable amount of time. Timely corrective actions were not taken

to correct a dual position indication (open and closed lights both illuminated) on the Unit

1 A train RHR containment sump suction flow control valve 1-FCV-63-72.

Description: On August 8 at 0709, the Unit 1 control room operator noted that valve 1-

FCV-63-72 showed dual position indication on the control board. This valve is the A

train RHR suction valve from the reactor containment sump and is normally closed,

showing only a single position indication lamp on the control board. Valve 1-FCV-63-72

was verified to be locally closed. No other activities were noted that would have caused

the valve to come off its closed seat. Initial troubleshooting for the dual indication

consisted of: 1) a visual inspection of the valve; 2) a visual inspection of the motor

control center (MCC) cubicle during an attempted closure of the valve; 3) a review of the

wiring diagram by a troubleshooting team; 4) replacement of the MCC light indicating

bulb; and 5) a visual inspection of the main control room (MCR) hand switch. Based on

the troubleshooting teams analysis of the wiring diagrams, no impact was expected on

the interlocks associated with 1-FCV-63-72. The team initially concluded that the most

likely cause of the indication was a short circuit in the control power indication in the

MCR valve hand switch. Based on this conclusion, plus the fact that the valve is not

normally stroked at power (due to concerns of accidently transferring borated water from

the RWST to the containment sump), the licensee chose not to immediately stroke test

1-FCV-63-72. Instead, the licensee declared the position indication for the valve

inoperable per Post Accident Monitoring requirements as delineated in TS 3.9.1. This

was a 30 day limiting condition for operation. The licensee then began development of a

troubleshooting plan which would require more intrusive troubleshooting of the issue

starting the following week.

On August 14 at 2315, during a routine quarterly inservice testing valve stroke activity,

valve 1-FCV-74-3 failed to stroke in the closed direction from the control room. This

valve is the A train RHR suction valve from the RWST and is normally open. Valve 1-

FCV-74-3 was immediately declared out of service and the 72-hour Emergency Core

Cooling Systems (ECCS) TS 3.5.2 action statement was entered. During

troubleshooting, operators attempted to close valve 1-FCV-74-3 remotely from the MCC

cubicle. This action blew control power fuses. The licensee then attempted local

manual operation and noted 1-FVC-74-3 could be manually closed without binding.

Valve 1-FCV-74-3 was partially manually closed and then reopened from the MCC

without incident. Due to the relationship between valves 1-FCV-63-72 and 1-FCV-74-3

(interlocks, shared wiring in junction boxes, etc.) the licensee suspected that the failure

of valve 1-FCV-74-3 to close and valve 1-FCV-63-72 dual position indication were

related.

Enclosure

25

The licensee subsequently opened the 1-FCV-63-72 actuator and noted that a

significant amount of water had accumulated inside the actuator. This water caused

significant electrical shorting in the valve control circuit and rendered the valve

inoperable. Also, the water affected valve 1-FCV-74-3, as this valve utilizes contacts

from valve 1-FCV-63-72 circuitry. It was noted that a low current short caused the failure

of the closing coil for valve 1-FCV-74-3. Following repairs to both 1-FCV-63-72 and

1-FCV-74-3, the ECCS system was returned to operable status on August 17 at 0200.

The licensees past operability determination concluded that 1-FCV-63-72 and 1-FCV-

74-3 were likely inoperable beginning on August 8 when 1-FCV-63-72 was noted to have

a dual indication. Thus the A train ECCS system was most likely inoperable for

approximately nine days, which exceeded the TS allowable outage time. On October

21, 2013, Licensee Event Report 50-327/2013-003 was submitted as a result of this

issue. The licensee concluded that the source of the water was ground water that had

migrated through the concrete ceiling that housed the valve and actuator cables. The

ground water leaked through the threaded penetration seal and inside the conduit and

flowed down into the valve actuator. During the most recent Unit 1 refueling outage in

November 2013, the licensee redesigned the conduit penetration to prevent the intrusion

of moisture into the conduit. The licensee noted the rate of moisture intrusion was most

likely higher in the recent months due to a higher than normal amount of rainfall that

temporarily raised the water table in the vicinity of the plant. The inspectors also noted

that on February 29, 2012, the licensee discovered water buildup in the actuator of 1-

FCV-63-72. This deficiency was entered into the CAP; however it appears that this

precursor was not adequately evaluated such that continued water intrusion ultimately

led to the failure noted on August 8, 2013.

Analysis: The licensees failure to take timely actions to correct a condition adverse to

quality was a performance deficiency. The inspectors concluded that testing and

inspection could have determined that valve 1-FCV-63-72 was inoperable much earlier

than August 14 when it was noted that RHR suction valve to the RWST, 1-FCV-74-3, did

not pass its routine surveillance test. This finding was determined to be more than minor

because it was associated with the Design Control attribute of the Mitigating Systems

cornerstone and adversely affected the cornerstones objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences (i.e., core damage). Specifically, the finding reduced the

reliability and capability of the A train RHR system to perform its safety function as

designed. Using IMC 0609.04, Initial Characterization of Findings, dated June 19,

2012, and IMC 0609, Appendix A, Exhibit 4 - External Events Screening Questions,

dated June 19, 2012, the finding required a detailed risk analysis as the A RHR system

was inoperable beyond its TS-allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The detailed risk

analysis concluded that the finding was of very low safety significance (Green).

A Phase 3 analysis was performed by the regional Senior Reactor Analyst to determine

the impact of the finding. The analysis assumed a recoverable failure of the 1-FCV-63-

72 valve, along with a dependent failure of the 1-FCV-74-3 valve. The major impacts

were in the swapover from the RWST to the containment sump as the source of water to

Enclosure

26

mitigate medium and smaller LOCA sequences. Because of the low exposure time, the

availability of the opposite train, and the ability of the operations staff to operate the

effected valves manually, the finding was determined to be Green.

The cause of this finding was determined to have a cross-cutting aspect relating to the

proper classification, prioritization, and evaluation of operability and reportability of

conditions adverse to quality in the Corrective Action component of the Problem

Identification and Resolution area, in that, on February 29, 2012, the licensee discovered

water buildup in the actuator of 1-FCV-63-72 and did not adequately evaluated the

condition adverse to quality such that continued water intrusion ultimately led to the

failure noted on August 8, 2013. P.1(c)

Enforcement: Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion

XVI, Corrective Action, requires, in part, that measures shall be established to assure

that conditions adverse to quality, such as failures, malfunctions, deficiencies,

deviations, defective material and equipment, and non-conformances are promptly

identified and corrected. Contrary to the above, from August 8 through August 17, 2013,

the licensee failed to assure that a condition adverse to quality, the failure of valve FCV-

63-72, was corrected in a timely manner. Specifically, the licensee failed to sufficiently

evaluate and correct a moisture intrusion problem associated with the RHR containment

suction motor-operated valve. Corrective actions taken by the licensee included

redesigning and modifying the conduit penetration to prevent the intrusion of moisture

into the conduit. The violation was entered into the licensees CAP as PER 772193.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the

Enforcement Policy and will be identified as NCV 05000327/2013005-01, Unit 1 Train

A RHR Containment Suction Valve Failure.

.2 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force

personnel and activities to ensure that the activities were consistent with licensee

security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities

did not constitute any additional inspection samples. Rather, they were considered an

integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings were identified.

Enclosure

27

.3 Review of the Operation of an Independent Spent Fuel Storage Installation (ISFSI)

(60855.1)

a. Inspection Scope

The inspectors performed a walkdown with the field operator of the ISFSI storage pad on

December 26, 2013, to verify that operations were conducted in a safe manner in

accordance with approved procedures and without undue risk to the health and safety of

the public. The inspectors noted that there were 40 multi-purpose canisters (MPCs)

positioned on the ISFSI pad. The inspectors verified the MPC vents were in good

condition and free of obstruction. The inspectors also verified natural circulation within

the MPCs. The inspectors verified that any ISFSI problems were placed in the CAP.

The inspectors also reviewed ISFSI document control practices to verify that changes to

the required ISFSI procedures and equipment were performed in accordance with

guidelines established in local procedures and 10 CFR 72.48. Documents reviewed are

listed in the Attachment.

b. Findings

No findings were identified.

4OA6 Meetings

.1 Exit Meeting Summary

On January 13, 2014, the resident inspectors presented the inspection results to Mr.

Carlin and other members of his staff, who acknowledged the finding. The inspectors

asked the licensee whether any of the material examined during the inspection should

be considered proprietary. No proprietary information was identified.

ATTACHMENT: SUPPLEMENTARY INFORMATION

Enclosure

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Alfultis, Director of Modifications & Projects

J. Carlin, Site Vice President

J. Cross, Chemistry Manager

A. Day, Radiation Protection Manager

D. Erb, Work Control Manager

M. Henderson, ISI Program Engineer

H. Hill, Rad Waste Superintendent

J. Johnson, Program Manager Licensing

A. Little, Site Security Manager

K. Loomis, Boric Acid Program Engineer

T. Marshall, Operations Manager

M. McBrearty, Licensing Manager

S. McCamy, Quality Assurance Manager

S. Mohorn, Rad Waste Superintendent

P. Noe, Director Safety and Licensing

C. Owens, Rad Waste HP

W. Pierce, Site Engineering Director

P. Pratt, Manager, Maintenance

J. Rolph, Radiation Protection Technical Support Superintendent

P. Simmons, Plant Manager

K. Smith, Director of Training

D. Sutton, Licensing

J. Stamey, Rad Waste Health Physicist

J. Stewart, Chemist

NRC personnel

S. Lingam, Project Manager, Office of Nuclear Reactor Regulation

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000327/2013005-01 NCV Unit 1 Train A RHR Containment Suction

Valve Failure (Section 4OA5)

Closed

05000327/2013004-01 URI Water Intrusion Into Actuator of Valve 1-

FCV-63-72 (Section 4OA5)

Attachment

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

0-PI-OPS-006.0, Freeze Protection, Rev. 55

Service Requests (SRs)

SR 807550

SR 825408

SR 821489

Section 1R04: Equipment Alignment

Partial System Walkdowns

Procedures

0-GO-16, System Operability Checklists, Rev. 4

Other documents

UFSAR Section 9

Procedures

0-SI-OPS-030-021.A, Auxiliary Building Gas Treatment System Train A, Rev. 6

0-SI-OPS-030-021.B, Auxiliary Building Gas Treatment System Train B, Rev. 6

0-SO-30-18, Auxiliary Building Gas Treatment System, Rev. 14

0-SO-65-1, Emergency Gas Treatment System Air Cleanup and Annulus Vacuum, Rev. 27

0-SO-30-1, Control Building Heating, Air Conditioning, and Ventilation, Rev. 39

0-SO-30-10, Auxiliary Building Ventilation Systems, Rev. 54

Section 1R05: Fire Protection

Procedures

FPDP-1, Conduct of Fire Protection, Rev. 2

0-PI-FPU-317-299.W, Att. 8, Shift Check List, Rev. 32

NPG-SPP-18.4.7, Control of Transient Combustibles, Rev. 0

EITP-100, Environmental Compliance, Rev. 6

0-SI-FPU-410-703.0, Inspection of FPR Required Fire Doors, Rev. 5

SQN-FPR-Part-II, SQN Fire Protection Report Part II - Fire Protection Plan, Rev. 28

Other documents

Fire Protection Pre-Fire Plans for Unit 1 Lower Containment Building

Fire Protection Pre-Fire Plans for Unit 2 Lower Containment Building

Fire Protection Pre-Fire Plans for Control Building Elevation 685 (Auxiliary Instrument Room)

Fire Protection Pre-Fire Plans for Control Building Elevation 706 (Cable Spreading Room)

Fire Protection Pre-Fire Plans for ERCW Building - Elevations 688/704/720

Fire Protection Pre-Fire Plans for Turbine Building - Elevations 662/685

Section 1R06: Flood Protection Measures

Work Orders

WO 11108121224, Check Standing Water Level in Manholes/Handholes

Enclosure

3

Other documents

TVA letter to NRC dated May 4, 2007. TVA response to GL 2007-01

Section 1R08: Inservice Inspection Activities

Procedures

N-VT-15 - Visual Examination of Class MC and Metallic Liners of Class CC Components of

Light-Water cooled Plants, Rev. 11

N-VT-16 - General Visual Examination Containment Vessel Integrity Verification, Rev. 05

N-UT-67 - Generic Procedure for Straight Beam Ultrasonic Examination of Bolts and Studs,

Rev. 05

PDI-UT-5 - Generic Procedure for Straight Beam Ultrasonic Examination of Bolts and Studs,

Rev. D34

IEP-200 - Qualification and Certification Requirements for TVA Inspection Services

Organization (ISO) Nondestructive (NDE) Personnel, Rev. 13

Corrective Action Documents

PER 618770 - Boron buildup on 1B-B SIS Pump Pedestal

PER 691545 - Boric acid build up and wet boric acid are present on transmitter sensing line

1-ft-72-41

PER 01-010244 - Minor concrete voids in U1C11 Vt-3 inspection

PER 169175 - Airline cracks in ceiling beneath reactor cavity and reactor wall

SR 797854 - Hairline cracking in the concrete beneath the fuel transfer canal in lower

containment

SR 526607 - Spalling on baseplate of Protection Device No. 1 on Drawing 48N1701-17.

SR 797166 - Boric acid on Reactor Coolant Pump #1 on #3 seal

SR 797061 - Boric acid on valve 1-FCV-063-0098

SR 797072 - Two areas of white deposit in Fan Room 2

Other documents

Periodic Instruction 0-PI-DXI-000-116.2, ASME Section XI IWE/IWL Containment Inservice

Inspection (CSI) Program, Rev. 05

Q-NIC-100 - Written Practice for the Qualification and Certification of Nondestructive

Examination (NDE0 Personnel, Rev. 20-TVA

IHI Southwest Technologies, Inc. Operating Procedure 2.0-NDES-001, Nondestructive

Examination Personnel Qualification and Certification, Rev. 06

WO 113312025 - Modify Component Cooling Piping to eliminate interference with actuator for

1-FC-063-011

Section 1R12: Maintenance Effectiveness

Procedures

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

10CFR50.65, Rev. 23

Other documents

MR 11th Periodic Assessment Report (PE sample)

Cause Determination and Evaluation (CDE) #2700, FCV-63-72 Failure

CDE #2696, EBGTS B Fan Failure

Attachment

4

CDE #2686, A Shutdown Boardroom Chiller Failure

CDE #2674, B Main Condenser Test Connection Failure

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

0-TI-DSM-000-007.1, Risk Assessment Guidelines, Rev. 9

NPG-SPP-07.3, Work Activity Risk Management Process, Rev. 3

NPG-SPP-07.2.4, Forced Outage or Short Duration Planned Outage Management, Rev. 0

NPG-SPP-07.2, Outage Management, Rev. 0

GOI-6, Apparatus Operations, Rev. 142

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

NEDP-22, Functional Evaluations, Rev. 9

OPDP-8, Limiting Conditions for Operation Tracking, Rev. 5

NPG-SPP-03.5, Regulatory Reporting Requirements, Rev. 2

PERs

789552 - Unit 2 Turbine Controls in Manual

795451 - POE WO 113223153 T1 motor lead pinch

799097 - POE TS LCO 3.7.4 action for FCV-67-146

800432 - POE (ABSCE boundary issue)

795433 - PDO (During U1R19 water found leaking out of conduit in bioshield wall)

801415 - PDO EDG 1B 2 sec load sequence

803833 - PDO U-1 Rx Head Vent Valve Stroke

816731, 815638, 817841 - FEs associated with the Unit 1 loose parts alarm

Section 1R18: Plant Modifications

Procedures

NPG-SPP-09.3, Plant Modifications and Engineering Change Control, Rev. 4

NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments, Rev. 1

NPG-SPP-09.5, Temporary Alterations, Rev. 0

Other documents

DCN 22643 - Replace Pressurizer PORVs

Section 1R19: Post Maintenance Testing

Procedures

MMDP-1, Maintenance Management System, Rev. 20

MMDP-3, Guidelines for Planning and Execution of Troubleshooting Activities, Rev. 6

NPG-SPP-6.5, Foreign Material Control, Rev. 0

NPG-SPP-6.1, Work Order Process Initiation, Rev. 0

NPG-SPP-06.3, Pre-/Post-Maintenance Testing, Rev. 0

NPG-SPP-06.9, Testing Programs, Rev. 0

NPG-SPP-06.9.1, Conduct of Testing, Rev. 1

NPG-SPP-06.9.3, Post-Modification Testing, Rev. 0

Attachment

5

Work Orders

114306842 - Disassemble and reassemble valve in support of 113716425

114306841 - Remove actuator, install actuator, set up calibration in support of 113716425

114325805 - Disassemble and reassemble valve in support of 113716459

114325799 - Remove and install actuator in support of 113716459

113756597 - PORVs - PCV-68-340 & pcv-68-334 Replacement activities

113377829 - Repack Valve (1-LCV-3-175) and perform AIRCET test

112096045 - Repair isolation check valve (1-VLV-026-1296)

111234712 - 5 year PM to swap 480V Shutdown board breaker with a refurbished breaker

113806636 - Perform 0-MI-EPM-317-102.0 on CCS pump C-S and clean/replace motor air filter

114560807 - CCP room cooler fan motor current check, bearing lubrication and cleaning

114198329 - EQ maintenance and inspection

113408190 - Change out electrolytic capacitors in the Woodward 2301A governor card

Section 1R20: Refueling and Other Outage Activities

Procedures

FHI-3, Movement of Fuel, Rev. 65

0-GO-15, Containment Closure Control, Rev. 34

0-GO-13, Reactor Coolant System Drain and Fill Operations, Rev. 71

NPG-SPP-08.1, Nuclear Fuel Management, Rev. 00

0-PI-OPS-000-011.0, Containment Access Control During Modes 1-4, Rev. 1

Section 1R22: Surveillance Testing

Procedures

NPG-SPP-06.9.1, Conduct of Testing, Rev. 8

0-SI-SXV-072-266.0, ASME Code Valve Testing, Rev. 12

0-SI-OPS-068-137.0, Reactor Coolant System Water Inventory, Rev. 32

0-SI-SFT-072-138.0, Unit 1 Containment Spray - Spray Nozzle Test, Rev. 6

0-SI-SLT-081-258.1, Unit 1 Primary Water LLRT, Rev. 5

0-SI-SLT-088-259.1, Upper Personnel Airlock Overall Leak Rate Test and General Inspection,

Rev. 6

0-SI-SLT-088-259.4, Upper Personnel Airlock Interlock Operability Test, Rev. 2

1-SI-SXP-003-202.B, Motor Driven Auxiliary Feedwater Pump 1B-B Comprehensive

Performance Test, Rev. 7

1-SI-SXP-074-202.0, RHR Pump 1A-A and 1B-B Comprehensive Performance and Check

Valve Test, Rev. 10

0-SI-OPS-068-137.0, Reactor Coolant System Water Inventory, Rev. 32

1-SI-OPS-088-001.0, Phase A Isolation Test, Rev. 14

1-SI-OPS-082-026A, Loss of Offsite Power with Safety Injection D/G 1A-A Test, Rev. 46

0-SI-SFT-072-138.0, Unit 1 Containment Spray - Spray Nozzle Test, Rev. 6

0-SI-SXV-063-203.2, Full Stroking of Safety Injection Cold Leg Accumulator Isolation Valves,

Rev. 1

0-SI-MIN-061-105.0, Ice Condenser Ice Weighing, Rev. 11

0-SI-SLT-067-258.2, Containment Isolation Valve Local Leak Rate Test Lower Compartment

Essential Raw Cooling Water, Rev. 13

PERs

801081, FME concern while performing air flow test during core reload

Attachment

6

Other documents

1-47W437-4, Mechanical Containment Spray System Piping, Rev. 1

1-47W437-5, Mechanical Containment Spray System Piping, Rev. 4

1-47W812-1, Flow Diagram Containment Spray System, Rev. 45

Technical Specification Surveillance Requirement 4.6.2.1.1.d and 4.6.2.1.2.b

Section 1EP2: Alert and Notification System Evaluation

Procedures and Reports

NP-REP, Appendix B, Sequoyah Nuclear Plant Radiological Emergency Plan, Rev. 101

EPFS-9, Inspection, Service, and Maintenance of the Prompt Notification System (PNS) at

Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants, Rev. 8

Sequoyah FEMA REP-10 Report, Revision 2

EPDP-10, Facilitation of the ANS and Notification Tests, Rev. 6

EPDP-14, Evaluation of Changes to Alert and Notification Systems (ANS), Rev 0

Records and Data

Weekly Silent Tests, 2011-September 2013

Monthly Siren Tests, October 2011 - October 2013

Corrective Action documents

442747; During Monthly Siren Test Five Sirens Did Not Operate

521663; Siren Damaged by Storm

591666; Two ANS Sirens Failed to Operate During Monthly Test

701363; Siren Relocations Due to Land Owner Rejections

711912; Loss of DC Power Indication for ANS Siren 12

727891; Loss of DC Power Indication for ANS Siren 26

751936; Two ANS Sirens Failed to Operate During Monthly Test

Section 1EP3: Emergency Response Organization Staffing and Augmentation System

Procedures

TRN-30, Radiological Emergency Preparedness Training, Rev. 24

EPDP-3, Emergency Plan Exercises and Preparedness Drills, Rev. 7

EPDP-10, Facilitation of the Alert and Notification System and Pager Tests, Rev. 6

EPIP-3, Alert, Rev 36

EPIP-6, Activation and Operation of the Technical Support Center, Rev. 49

EPIP-7, Activation and Operation of the Operations Support Center, Rev. 28

Records and Data

SQN-EP-S-13-02, snapshot self-assessment SCBA Qualification of Site Personnel, March 2013

EPT202.000, ERO Training Plan - TSC Training, Rev. 12

EPT900.010, ERO Training Plan, ERO Fundamentals, Rev. 4

Radiological Emergency Preparedness Training Oversight Committee minutes 2012/2013

2012/2013 ERO Augmentation test results

Results of periodic ERO notification tests

Corrective Action documents

786990; TRN error in CECC qualification requirement

Attachment

7

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Change Packages

TVA Radiological Emergency Plan, Revs. 99 and 100

EPIP-1, Emergency Plan Classification Matrix, Revs. 48 and 49

CECC EPIP-2, Operations Duty Specialist Procedure for Notification of Unusual Event,

Rev. 43

CECC EPIP-3, Operations Duty Specialist Procedure for Alert, Rev. 44

CECC EPIP-4, Operations Duty Specialist Procedure for Site Area Emergency, Rev. 45

CECC EPIP-5, Operations Duty Specialist Procedure for General Emergency, Rev. 50

CECC EPIP-7, CECC Radiological Assessment Staff Procedure for Alert, Site Area

Emergency, and General Emergency, Rev. 34

TVA Radiological Emergency Plan, Rev. 101

Evacuation Time Estimate Study Update

Section 1EP5: Maintenance of Emergency Preparedness

Procedures

CECC EPIP-9, Emergency Environmental Radiological Monitoring Procedures, Rev. 49

EPDP-17, NPG Emergency Plan Effectiveness Review [10 CFR 50.54(q)], Rev. 3

NPG-SPP-7.1, On-Line Work Management, Rev. 10

NPG-SPP-18.3.5, Designated Emergency Response Equipment (DERE), Rev. 0

NPG-SPP-22.300, Corrective Action Program, Rev. 0

Records and Data

Drill and exercise reports 2011-2013

TVA Quality Assurance Audit Report SSA 1203 dated April 16, 2012

TVA Quality Assurance Audit Report SSA 1305 dated June 17, 2013

Focused Self-Assessment SQN-EP-F-13-001, NRC Inspection Preparation

SQN QA Quarterly Rating Report August 13, 2013

Corrective Action documents

571999; Maintenance Personnel Not Evacuated in a Timely Manner During REP Drill

572584; RP Was Slow to Perform Airborne Sampling During REP Drill

608785; Dose assessment error

581795; No Additional Fire Brigade Personnel Onsite During REP Drill

582858; TSC SED Filled Out Wrong Form Which Delayed CECC PAR Development

582751; MERT Failed 4 of 6 Drill Objectives

619808; RP Tech Left Team to Get Equipment During Graded Exercise

619847; Inside Van Tech Did Not Grab All Equipment Required During Graded Exercise

695758; MET Unavailable - Lessons Learned

704845; Evaluate EPIP-1 Classification of EAL 4.2 for Explosion

708940; Questioned CET Readings During Drill

711961; REP Assignment Cannot Meet 1-Hour Requirement to Respond

720352; 8 Personnel Were Not Accounted For During REP Drill

722951; KI Tablets Should Be Evaluated for Issue Earlier Under Emergency Conditions

732171; Clarify EPDP-11 regarding 10 CFR 50.54(t) requirements

751183; Wrong Pocket Ion Chambers in REP Van #3

Attachment

8

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedures, Guidance Documents, and Manuals

NPG-SPP-05.1.1, Alpha Radiation Monitoring Program, Rev. 3

NPG-SPP-05.6, Controlling Byproduct and Source Material, Rev. 2

NPG-SPP-22.300, Corrective Action Program, Rev. 0

RCDP-1, Conduct of Radiological Controls, Rev. 5

RCI-01, Radiation Protection Program, Rev. 78

RCI-14, Radiation Work Permit (RWP) Program, Rev. 57

RCI-15, Radiological Postings, Rev. 24

RCI-17, Control of Byproduct and Source Material, Rev. 19

RCI-18, Vacuum Cleaner Control Within the Radiologically Controlled Area, Rev. 9

RCI-21, Control of Radioactive Materials, Rev. 19

RCI-29, Control of Radiation Protection Keys, Rev. 15

RCI-101, Radiation Operations Routines, Rev. 3

RCI-106, Radiation Protection Standards and Expectations, Rev. 3

RCI-201, Radiation and Contamination Surveys, Rev. 13

RCI-202, Airborne Radioactivity Surveys, Rev. 7

RCI-204, Radiological Surveys of Equipment and Materials Leaving the RCA, Rev. 7

RCI-209, Radiological Surveys of Personnel Leaving the RCA or Protected Area, Rev. 3

RCI-301, Radionuclide Tracking and Assessment (RTA) Program, Rev. 2

RCI-412, Radiation Protection Surveys during Initial Spent Fuel Assembly Movement, Rev. 1

RCI-417, Radiological Monitoring of the Hydrogen Peroxide Injection Crud Burst, Rev. 1

RCTP-106, Special Dosimetry Operations, Rev. 2

0-TI-NUC-000-002.0, Storing Material in Spent Fuel Pool or New Fuel Vault, Rev. 21

Records and Data

Air Sample Detail Report for 10/13/2013 thru 11/5/2013, 11/5/2103

Air Sample 101713018, U1 Equipment Pit, 10/17/2013

Air Sample 101813018, U1 734 RFF GA, 10/18/2013

Air Sample 102313006, U1 Rx Head Stand, 10/23/2013

Air Sample 102313014, U1 653 1B RHR Pump Room, 10/23/2013

Air Sample 102313023, U1 653 1B RHR Pump Room, 10/23/2013

Air Sample 102613003, U1 Upper Rx Head O-ring Cleaning, 10/26/2013

Air Sample 110213012, U1 Upper GA, 11/2/2013

ALARA Plan 2013-010, Refueling Operations

ALARA Plan 2013-011, Mechanical Maintenance Group (MMG)

ALARA Plan 2013-018, MODS - Ice Condenser/Snubbers/Insulation/Scaffolds/Painting

Instrument Calibration/Check Source Certificates:

Vendor Source No. I3-328, TVA No. 2530, 7/29/2011

Vendor Source No. I3-329, TVA No. 2531, 7/29/2011

Vendor Source No. I3-330, TVA No. 2532, 7/29/2011

Vendor Source No.G4-975, TVA No. 2483, 10/9/2009

Vendor Source No. 92421, TVA No. 2571, 12/7/2012

Vendor Source No. 52736-185D2, TVA No. 2245, 5/19/2003

Instrument Calibration Records:

Canberra GEM-5 Personnel Monitor, Serial No. 0909-179, 3/23/2012 and 3/18/2013

ARGOS-5AB Personnel Monitor, Instrument No. 860587, 5/11/2012 and 5/2/2013

iSolo, Instrument No. 860494, 12/6/2012 and 10/11/13

Attachment

9

Small Article Monitor (Cronos 11), Instrument No. 860653, 8/17/2012 and 7/16/2013

Small Article Monitor (SAM-11), Instrument No. 860325, 7/6/2012 and 11/17/2012

List of Active SQN Temporary Shielding Request Forms (TSRFs), 11/6/2013

National Source Tracking System Annual Inventory Reconciliation Confirmation, 1/24/2013

National Source Tracking System Inventory Report, Sequoyah Nuclear Plant, 1/24/2013

RWP Dose by Work Step Report for ALARA Plans 2013-010 to 2013-021 for the period

10/14/2013 thru 11/6/2013

RWP Total Dose, Hours and Dose Rate Report for the period 10/14/2013 thru 11/5/2013

RWP Work Step Dose and Dose Rate Alarm Setpoints for RWP 13140052, 11/5/2013

RWP 13120122, U1 Seal Table work

RWP 13140002, U1 Upper Containment High Rad Area Mechanical Maintenance

RWP 13140052, HRA U1 Refueling Activities for AREVA and Boilermakers

RWP 13140072, U1 HRA MODS Work: Snubbers, Scaffold, Insulation, Painting

RWP 13140172, U1 Rx Head Insulation

RWP 13140252, HRA U1 Upper Containment Rx Cavity

RWP 13140352, U1 HRA Head O-Ring Surface Work & Inspection (Multibadging)

RWP 13140353, U1 Equipment Pit - LHRA Vortex Suppressors

RWP 13140453, U1 Upper Containment, Rx Cavity, LHRA, CRDM duct work, (Multibadging)

Radiological Survey SQN-M-20131014-23 and SQN-M-20131104-2, U1 Containment

Equipment Pit

Radiological Survey SQN-M-20131021-3, SQN-M-20131014-6, SQN-M-20131014-15, and

SQN-M-20131014-22, U1 Containment Accumulator Rooms #1, #2, #3, and #4

Radiological Survey SQN-M-20131014-32 and SQN-M-20131017-9, U1 Containment Top of

Pressurizer

Radiological Survey SQN-M-20130909-1 and SQN-M-20131014-8, U1 Containment Raceway

Radiological Survey SQN-M-20131014-14, SQN-M-20131014-7, and SQN-M-20131014-5, U1

Containment Steam Generator Primary Platform #1, #2, and #3

Radiological Survey SQN-M-20131014-17 and SQN-M-20131020-7, U1 Containment Inside

Polar Crane Wall

Radiological Survey SQN-M-20131021-21, SQN-M-20131014-10, and SQN-M-20131014-18,

U1 Containment RCP Platform #1, #2, and #3

Radiological Survey SQN-M-20131020-16, SQN ISFSI Pad

Radiological Survey SQN-M-20121212-8, U2 Letdown Heat Exchanger Room

Radiological Survey SQN-M-20131014-26, U1 Letdown Heat Exchanger Room

Radiological Survey SQN-M-20130502-11 and SQN-M-20131005-1, U1 651' Waste Evaporator

Feed Pump Room

Radiological Survey SQN-M-20131018-1 and SQN-M-20131025-1, Radiochemistry Lab

Radiological Survey SQN-M-20130617-3, SQN-M-20131007-1, and SQN-M-20131104-4,

Equipment Decon Room

Radiological Survey SQN-M-20130823-3, and SQN-M-20131016-24, Spent Fuel Heat

Exchanger Room

Radiological Survey SQN-M-20130920-5, SQN-M-20131020-4, and SQN-M-20131028-7, Spent

Fuel Pool Area

Radiological Survey SQN-M-20131015-8, SQN-M-20131020-9, and SQN-M-20131024-7, 1A

RHR Pump Room

Radiological Survey SQN-M-20131015-11, SQN-M-20131022-8, and SQN-M-20131023-10, 1B

RHR Pump Room

Radiological Survey SQN-M-20131101-10, 2B RHR Pump Room

Attachment

10

Radioactive Sealed Source Leak Test Certification, Source ID 0413-00-00, 7/23/09 and 1/25/10

Sequoyah Nuclear Plant Annual Radionuclide Trending and Assessment Report for 2011,

6/30/2012

Sequoyah Nuclear Plant Annual Radionuclide Trending and Assessment Report for 2012,

4/18/2013

U1R19 Radiation Protection Status Report, 11/5/2013

U1R19 RCS Shutdown Co-58 Activity Graphs (Crud Burst Cleanup), 11/5/2013

U1R19 Crud Burst Cleanup Dose Rate Trending Graphs (1A and 1B RHR Pump and Heat

Exchanger rooms, and 690 and 669 Pipe Chases near RHR Lines), 11/5/2013

Waste Stream Report (10 CFR Part 61 Waste Characterization), DAW 10-22-2010, 5/11/2011

Waste Stream Report (10 CFR Part 61 Waste Characterization), DAW 3-22-2012, 11/4/2012

WO 114067330, 0-SI-RCI-000-056.0 Byproduct Material Inventory and Sealed Source Leak

Test, 7/8/2013

WO 114139751, 0-SI-RCI-000-056.0 Byproduct Material Inventory and Sealed Source Leak

Test, 12/17/2012

CAP Documents

Apparent Cause Evaluation PER Report, SQN PER 782859, 10/20/2013

Site Audit Report SSA1309, Radiation Protection Sequoyah Nuclear Plant, 9/16/2013

TVA Nuclear Power Group Benchmarking Report SQN-RP-I-13-BM09, 8/23/2013

PERs

PER 626962

PER 629341

PER 657724

PER 659369

PER 782859

PER 788604

PER 790597

PER 793236

PER 793935

PER 799256

PER 802329

Section 2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling,

Storage, and Transportation

Procedures, Manuals, and Guides

Energy Solutions Cask Book for Model 8-120B USA/9168/B(U)

NPG-SPP-05.7, Radwaste Management, Rev. 0

Process Control Program (PCP), Rev. 4

Radioactive Material Shipment Manual (RMSM, Vol.II -Radioactive Material Shipment, Rev. 42

Radioactive Material Shipment Manual (RMSM, Vol.III -Radwaste Shipment, Rev. 39

RCI-06, Receipt of Radioactive Materials, Rev. 19

RCI-21 Control of Radioactive Materials, Rev. 19

RHSI-1, Packaging Dry Active Waste for Shipment to a Waste Processor/Broker or a

Commercial Radwaste Burial Facility, Rev. 10

RHSI-1.1, Packaging Filters and Items of High Levels of Radiation, Rev. 6

Attachment

11

RHSI-6, Bead Resin Activated Carbon Dewatering Procedure for Energy Solutions14-215 or

Smaller Liners, Rev. 8

RHSI-7, Utilization of Polyethylene High Integrity Containers (HICs) and HIC Overpacks, Rev. 9

RHSI-11, Control of Radioactive Material and Training, Rev. 6

RHSI-13, Administration and Control of Onsite Storage of Low Level Radioactive Waste, Rev. 4

RWTP-100 Attachment A, Radwaste Training Program, Rev. 3

RWTP-100, Radioactive Material/Waste Shipments, Rev. 7

RWTP-101, 10 CFR 61 Waste Characterization, Rev. 2

RWTP-102, Use of Casks, Rev. 2

0-SO-77-29, Waste Processing, Rev. 9

0-VI-RCI-077-001.0, Operating Procedure for Duratek Modular Fluidized Transfer Demineralizer

System (MFTDS), Rev. 2

Shipping Records and Radwaste Data

Two Design Change Notices were reviewed and both have been accomplished. The first

moved Radwaste liquid processing from the railroad bay into the drumming room that was in

effect at the start of the period which included back to November 2010 and the second

established a lift system to be used for the steam generator replacement in 2012 with a closure

date of 8/13/2013.

The licensee provided several drawings delineating abandoned equipment. The inspector

chose the abandoned boric acid evaporator system to review.

Shipments:

SNP-12-0111 (LQ)

SNP-13-0105 (SCO)

SNP-13-0109 (Type B)

SNP-13-0307 (LSA)

SNP-13-0504 (Type A)

CAP Documents

Site Audit Report SSA1309, Radiation Protection, August 19 through August 30, 2013

Snapshot Self-Assessment Report SQN-RP-S-13-004, Radioactive Solid Waste Processing and

Radioactive Material Handling, Storage and Transportation, July 29 through August 9, 2013

PERs

412285

431332

488136

635127

735591

765281

767526

783784

Attachment

12

Section 4OA1: Performance Indicator Verification

Procedures, Manuals, and Guides

NSDP-29, Tracking and Trending and NRC Performance Indicators, Rev. 6

NPG-SPP-02.2, Performance Indicator Program, Rev. 5

RCI-151, Radiation Protection Functional Area Performance Indicators, Rev. 1

PERs

621990

623246

626962

653648

655642

788604

793921

794437

Section 4OA2: Problem Identification and Resolution

Procedures

NPG-SPP-03.1, Corrective Action Program, Rev. 1

Section 4OA5: Other Activities

0-GO-17, Spent Fuel/Dry Cask Operations, Rev. 5

NPG-SPP-01.2, Administration of Site Technical Procedures, Rev. 9

NFTP-100, Fuel Selection for Dry MPC Storage, Rev. 5 completed for campaign #6

10CFR 72.48 Screening/Evaluation: EDC E22443C

SQN-DCS-300.11, Supplemental Cooling System Operation, Rev. 9

CTP-DCS-100.0, Dry Cask Storage Campaign Guidelines, Rev. 15

SQN-DCS-200.0, Dry Cask Campaign Review Program, Rev. 4

SQN-DCS-200.2, SQN-MPC-Loading and Transport Operations, Rev. 35

Attachment

LIST OF ACRONYMS

ABGTS auxiliary building gas treatment system

ALARA as low as reasonably achievable

ASME American Society of Mechanical Engineers

BACC boric acid corrosion control

CAP corrective action program

CCP centrifugal charging pump

CDE cause determination evaluation

CFR Code of Federal Regulations

CIV containment isolation valve

DAW dry active waste

DOT Department of Transportation

ECCS emergency core cooling system

ED electronic dosimeter

ERCW essential raw cooling water

FCV flow control valve

FME foreign material exclusion

HRA high radiation areas

IMC inspection manual chapter

IP inspection procedure

ISFSI independent spent fuel storage installation

ISI in-service inspection

MCC motor control center

MPC multi-purpose canister

NCV non-cited violation

NDE non-destructive examination

NEI Nuclear Energy Institute

PER problem evaluation report

PORV power operated relief valve

Radwaste radioactive waste

RCA radiologically controlled area

Rev revision

RHR residual heat removal

RS radiation safety

RTP rated thermal power

RWP radiation work permit

RWST refueling water storage tank

SDP significance determination process

SI safety injection

SR service request

SSC structure, system, or component

TS technical specification

TVA Tennessee Valley Authority

URI unresolved item

UT ultrasonic testing

UFSAR Updated Final Safety Analysis Report

WO work order

Attachment