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IR 05000327/2014005, 05000328/2014005, on 10/1 - 12/31/2014, Sequoyah Nuclear Plant, Units 1 and 2, Event Follow-up
	ML15035A300
Person / Time
Site:	Sequoyah
Issue date:	02/04/2015
From:	King M F; Reactor Projects Region 2 Branch 6
To:	Shea J W; Tennessee Valley Authority
References
	IR 2014005
	Download: ML15035A300 (30)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 February 4, 2015

Mr. Joseph 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 05000327/2014005 AND 05000328/2014005

Dear Mr. Shea:

On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Sequoyah Nuclear Plant, Units 1 and 2. On January 7, 2015, 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.

No NRC-identified or self-revealing findings were identified during this inspection. However, inspectors documented a licensee-identified violation which was determined to be of very low safety significance. The NRC is treating this violation as a noncited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the 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.

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 NRC's Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Managem ent 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/ Michael King, Chief Reactor Projects Branch 6

Division of Reactor Projects Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79

Enclosure: Inspection Report 05000327/2014005, 05000328/2014005 w/Attachment: Supplementary Information

cc: via ListServ distribution

___________________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE DRS DRS DRS TTC RII:DRP RII:DRP RII:DRP SIGNATURE /VIA By E-mail/ /VIA By E-mail/ /VIA By E-mail/ /VIA By E-mail/ /VIA By E-mail/ /VIA By E-mail/ /RA/ NAME R. Baldwin A. Goldau P. Capehart KKorth GSmith WDeschaine CKontz DATE 1/29/2015 1/29/2015 1/29/2015 1/29/2015 1/25/2015 1/29/2015 2/3/2015 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE DRP SIGNATURE /RA/ NAME M. King DATE 2/3/2015 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO Letter to from Michael King dated February 4, 2015

SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000327/2014005 AND 05000328/2014005

Distribution

S. Price, RII L. Gibson, RII OE Mail RIDSNRRDIRS

PUBLIC RidsNrrPMSequoyah Resource

Enclosure U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79

Report Nos.: 05000327/2014005, 05000328/2014005 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, 2014

Inspectors: G .Smith, Senior Resident Inspector W. Deschaine, Resident Inspector K. Korth, Senior Reactor Technology Instructor R. Baldwin, Senior Operations Engineer P. Capehart, Senior Operations Examiner A. Goldau, Operations Engineer

Approved by: Michael King, Chief Reactor Projects Branch 6 Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000327/2014-005, 05000328/2014-005; 10/1-12/31/2014; Sequoyah Nuclear Plant, Units and 2; Event Follow-up

The report covered a three-month period of inspection by resident inspectors and announced inspections by regional inspectors. One violation was identified. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP) dated June 2, 2011. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.

A. NRC-Identified and Self-Revealing Findings

None

B. Licensee-Identified Violations

A violation of very low safety significance which was identified by the licensee was reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program (CAP). That violation and corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection

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

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Evaluation of Readiness for Seasonal Extreme Weather (Cold Weather) Conditions

a. Inspection Scope

The inspectors reviewed design features and licensee preparations for protection of the essential raw cooling water (ERCW) intake structure, main steam valve vault enclosures, both Unit 1 and 2 refueling water storage tanks (RWSTs), as well as other risk significant areas susceptible to extreme cold and freezing conditions. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and Technical Specifications (TS) in order to gain insights regarding freeze protection. The inspectors performed a detailed review of licensee procedure 0-PI-OPS-000-006.0, "Freeze Protection," Revision 58. This procedure was commenced on October 1 in order to ensure freeze protection equipment and strategies were implemented and executed prior to the onset of extreme cold weather. The inspectors reviewed all freeze protection-related service requests (SR) to ensure there were no significant deficiencies within the licensee's freeze protection program. The inspectors also walked down portions of the affected 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 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 three samples.

Unit 2 A-train Safety Injection (SI) system while the B SI pump was out-of service (OOS) for maintenance

Unit 2 A-train Charging system while the B charging pump was OOS for maintenance

Unit 1 B-train Containment Spray (CS) system while the 1A CS pump was OOS for maintenance

.2 Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of the Auxiliary Feedwater System (AFS) and support systems 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. The inspectors 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:

Valves were correctly positioned and did not exhibit leakage that would impact the functions of any given valve.

Electrical power was available as required.

Major system components were correctly labeled, lubricated, cooled, ventilated, etc.

Hangers and supports were correctly installed and functional.

Essential support systems were operational.

Ancillary equipment or debris did not interfere with system performance.

Tagging clearances were appropriate.

Valves were locked as required by the locked valve program.

Breakers were correctly positioned.

Visible cabling appeared to be in good material condition.

In addition, the inspectors reviewed outstanding maintenance work requests and design issues on the system to determine whether any condition described in those work requests could adversely impact current system operability. Documents reviewed are listed in the Attachment. The inspectors completed one sample.

b. Findings

No findings were identified.

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 licensee's 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 licensee's fire plan. Documents reviewed are listed in the Attachment. The inspectors completed six samples.

Auxiliary Building Elevation 690

Auxiliary Building Elevation 734

Auxiliary Building Elevation 749

Auxiliary Building Elevation 759

Condensate Demineralizer Waste Evaporator (CDWE) Building

Unit 2 Additional Equipment Building

b. Findings

No findings were identified.

.2 Annual Drill Observations

a. Inspection Scope

On October 15 and 24, 2014, the inspectors observed an announced fire drill in the 1A Unit board located in the turbine building and an unannounced fire drill in the Hydrogen tube trailer outside of Unit 2, respectively. The inspectors assessed fire alarm effectiveness; response time for notifying and assembling the fire brigade; the selection, placement, and use of firefighting equipment; use of personnel fire protective clothing and equipment (e.g., turnout gear, self-contained breathing apparatus); communications; incident command and control; teamwork; and fire fighting strategies. The inspectors also attended the post-drill critique to assess the licensee's ability to review fire brigade performance and identify areas for improvement. Following the critique, the inspectors compared their findings with the licensee's observations and to the requirements specified in the licensee's Fire Protection report. This activity constituted one inspection sample.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the performance test results of the Component Cooling Water heat exchangers 1A1 and 1A2 to verify that test results were appropriately categorized against the pre-established acceptance criteria described in procedure 1-PI-SFT-070-

001.0, Performance Testing of Component Cooling Heat Exchangers 1A1, 1A2, Revision 21. The inspectors also verified that the frequency of testing and inspection was sufficient to detect degradation prior to loss of heat removal capability below design basis values. The inspectors completed one sample

.

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 20, 2014. The training scenario involved a Power Range NI failing high, the 1B MFWP had increasing vibrations and trips, and then there was a Loss of Off-Site Power (LOOP) with the 1B-B Emergency Diesel Generator (EDG) failing to start automatically, and a reactor coolant system (RCS) leak of 400 gpm. 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. This activity constituted one inspection 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

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 Turbine Valve Testing

Unit 2 Turbine Valve Testing Documents reviewed are listed in the Attachment. This activity constituted one inspection sample.

b. Findings

No findings were identified

.3 Biennial Review of Licensed Operator Requalification

a. Inspection Scope

The inspectors reviewed the facility operating history and associated documents in preparation for this inspection. During the week of December 1 thru 4, 2014, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of operating tests and biennial written examinations associated with the licensee's operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, "Operators' Licenses." The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," and Inspection Procedure 71111.11, "Licensed Operator Requalification Program." The inspectors also evaluated the licensee's simulation facility for adequacy when used in operator licensing examinations using ANSI/ANS-3.5-1985, "American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination." The inspectors observed two shift crews during the performance of the operating tests. Documentation reviewed included written examinations, Job Performanc e Measures (JPMs), simulator scenarios, licensee procedures, on-shift records, simulator modification request records, simulator performance test records, operator feedback records, licensed operator qualification records, remediation plans, watch-standing records, and medical records. The records were inspected using the criteria listed in Inspection Procedure 71111.11. Documents reviewed during the inspection are documented in the List of Documents Reviewed.

This activity constituted one inspection sample.

b. Findings

No findings were identified.

.4 Annual Review of Licensee Requalification Examination Results:

a. Inspection Scope

On December 18, 2014, 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). 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." These results were compared to the thresholds established in Section 3.02, "Requalification Examination Results," of IP 71111.11. This activity constituted one inspection sample.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the maintenance activities, issues, and systems listed below to verify the effectiveness of the licensee's 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 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 structure, system, or components (SSCs) and functions classified as (a)(2); and appropriateness of goals and corrective actions for SSCs and functions classified as (a)(1). The inspector performed a review of the below listed Cause Determination Evaluations (CDE). The inspectors completed three samples.

CDE #2787 - 1B Charging Pump relay failure

CDE #2798 - Shield Building Rad Monitor failure

CDE #2799 - Trip of Vital Bus IV Battery Supply

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 w hether 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 licensee's 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 13, and Instruction 0-TI-DSM-000-007.1, "Risk Assessment Guidelines," Revision 10.

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

Unit 2 Emergent failure of LI-63-53, RWST Channel IV Level

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

For the five operability evaluations described in the problem evaluation reports (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 evaluations to UFSAR descriptions to determine if the system or component's 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 five samples.

PER 941069 - Station Blackout Air Cylinder (2-CYL-32-1950) Pressure Reading Below 1500 psig

PER 926080 - ERCW Pipe Support Failure

PER 952079 - Functional Evaluation of Boone Dam Sinkhole

PER 934663 - RHR Valve Failure During Recirculation

PER 904185 - West Saddle Dike Failure

b. Findings

No findings were identified.

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors reviewed the permanent modification listed below and the associated 10CFR 50.59 screening, and compared it against the UFSAR and TS to verify whether the modification affected operability or availability of the affected system. This modification implemented part of the Nuclear Energy Institute's (NEI) FLEX strategy to address mitigation efforts for beyond-design-basis external events. The modification utilized the existing additional diesel generator building (ADGB) as the location of newly installed 6.9KV/3MW FLEX diesel generators. Previously the ADGB housed the "5 th EDG" which had been previously abandoned-in-place. These two EDGs could be used in the event of an extended loss of all AC power. The new EDGs are located in a seismic class I structure and utilize a self-contained cooling system in contrast to the four existing safety-related EDGs which require ERCW cooling. The inspectors performed a design review of the modification which involved an evaluation of several key parameters including but not limited to: energy requirements of the supplied systems, material compatibility, environmental qualification, functional requirements, seismic requirements, unintended system interactions, barrier compromise, and fire-protection requirements. Documents reviewed are listed in the Attachment. The

inspectors completed one sample.

DCN 23197, 3MW FLEX EDG A & B Modification

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests associated with the two work orders (WOs) listed below to assess whether procedures and test activities ensured system operability and functional capability. The inspectors reviewed the licensee's 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 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 two samples.

WO 115713757, 2B Centrifugal Charging Pump room cooler belt replacement & lube

WO 115353846, Unit 1 Containment purge air supply fan 'A'

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the two 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 reviewing the test data. Documents reviewed are listed in the Attachment. The inspectors completed two samples.

In-Service Tests

1-SI-SXP-062-202.B, Boric Acid Transfer Pump 1B-B Performance Test, Revision 17 Routine Surveillance Tests

2-SI-SXP-070-201.A, Component Cooling Water pump 2A Section XI test, Revision 12

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

Resident inspectors evaluated the conduct of routine licensee emergency drill on October 22, 2014, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation (PAR) development activities. The inspectors observed emergency response operations in the simulated control room and the incident command post to verify that event classification and notifications were done in accordance with EPIP-1, Emergency Plan Classification Matrix, Revision 51. The inspectors also attended the licensee critique of the drill to compare any inspector observed weakness with those identified by the licensee in order to verify whether the licensee was properly identifying deficiencies. The inspectors completed one sample.

b. Findings

No findings were identified.

1EP7 Hostile Action (HA) Exercise

a. Inspection Scope

The resident inspectors participated in a complex HA emergency exercise on November 19, 2014 in order to identify any weakne sses and deficiencies regarding the NRC's interaction and coordination with the licensee during an event. The residents were in constant communications with headquarters-based personnel in Rockville, MD as well as region-based personnel located at the Central Emergency Control Center in Chattanooga, TN. The resident inspectors were stationed in the simulated control room and verified appropriate actions were performed by control room personnel in response to the event. The inspectors reported critical plant data and event updates to remote NRC personnel. The licensee's performance during the exercise was evaluated and graded by region-based personnel and was documented in NRC inspection report 2014-502 issued on December 19, 2014.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA2 Problem Identification and Resolution

.1 Daily Review

a. Inspection Scope

As required by Inspection Procedure 71152, Identification and Resolution of Problems, 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 licensee's CAP. This was accomplished by reviewing the description of each new service request and attending selected daily management review committee meetings.

b. Findings and Observations

No findings were identified.

.2 Selected Issue Follow-up:

PER 866924, "Apparent Cause Evaluation for Non-Conforming IST Pump Tests"

a. Inspection Scope

The inspectors performed a review regarding the licensee's assessments and corrective actions for PER 866924, "Apparent Cause Evaluation for Non-Conforming IST Pump Tests," to ensure that the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors also evaluated the PER against the requirements of the licensee's CAP as specified in procedure, NPG-SPP-22.300, "Corrective Action Program," Revision 2, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment. The

inspectors completed one sample

b. Findings and Observations

No findings were identified. In general, the inspectors verified that the licensee had proposed or implemented appropriate corrective actions.

.3 Semi-Annual Trend Review

a. Inspection Scope

As required by IP 71152, the inspectors performed a review of the licensee's CAP 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 considered the results of daily inspector CAP item screenings, licensee trending efforts, and licensee human performance results. This review nominally considered the six month period of July 2014 through December 2014 although some examples expanded beyond those dates when the scope of the trend warranted. The review also included issues documented outside the normal CAP in major equipment problem lists, focus area reports, system health reports, self-assessment reports, and department PIP trending reports. The inspectors compared and contrasted their results with the results contained in the licensee's latest quarterly trend reports. Documents reviewed are listed in the Attachment. The inspectors completed one sample

b. Findings and Observations

No findings were identified. In general, the licensee had identified trends and 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 Sample Review of Operator Work Arounds

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 licensee's workaround lists and repair schedules, reviewed CAP word searches, conducted tours and interviewed operators and operations department support staff. 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 and Observations

No findings were identified.

.5 Review of Licensed Operator Requalification

a. Inspection Scope

Due to emergent issues associated with the two crew failures observed while on site, the review focused on operator errors associated with usage of emergency operating procedures and classification of emergency plan emergency action levels (EALs). The listed SRs relate to various errors identified during the performance of licensed operator requalification (LOR). The inspectors reviewed the corrective actions associated with each of the service requests (SRs) and determined the corrective actions appeared appropriate and addressed the specific issue associated with implementing the emergency operating procedures and the emergency plan. In support of this assessment, the inspectors reviewed crew performance during the remediation and

reevaluation examination.

b. Findings

No findings were identified.

4OA3 Event Follow-up

(Closed) Licensee Event Report (LER) 2-2014-001-00, Misalignment of Containment Purge Radiation Monitors Results in Condition Prohibited by Technical Specifications

a. Inspection Scope

On April 29, 2014, during the performance of 0-SO-30-3, Containment Purge System Operation," the two containment purge air exhaust radiation monitors (SQN-2-RM-090-130 and SQN-2-RM-090-131) were discovered aligned to train A containment purge.

From April 8 to April 28, 2014, train B containment purge was operated three times with both radiation monitors aligned to train A purge. The containment purge radiation monitors provide containment ventilation isolation (CVI) signals upon a high radiation condition to mitigate the release of radioactivity from inside containment. With the radiation monitors not aligned to the train of containment purge exhaust being operated, the ability to signal a CVI from the containment purge exhaust monitors was lost.

However, during the time frame the purge monitors were misaligned, alternate automatic and manual means of performing a CVI were available. The event was documented in the licensee CAP as PER 878321.

The inspectors reviewed the LER, PER and Root Cause Evaluation Report to verify that the cause of the event was identified and that corrective actions were appropriate. The cause of the event was determined to be operators failing to perform verbatim procedure compliance when ensuring the containment purge radiation monitor was in alignment prior to placing containment purge in service. The inspectors concluded that the licensee's corrective actions were appropriate, including reinforcement of management expectations for procedure use and adherence with shift managers and crew operators.

The inspectors verified that timely notifications were made in accordance with 10 CFR 50.73. This LER is closed.

b. Findings

A violation of very low safety significance was identified by the licensee and is dispositioned in Section

4OA7 of this report.

4OA5 Other Activities

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

(60855.1)

a. Inspection Scope

During the week of Dec 15 to Dec 19, 2014, the inspectors reviewed the seventh dry-cask-loading campaign of the ISFSI 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 observed fuel loading operations and other processes on several multi-purpose canisters (MPCs) to verify that the specified fuel assemblies were placed in the correct locations and that other MPC processes were implemented in accordance with approved procedures. The inspectors reviewed problem reports discovered during the campaign to ensure that issues were placed in the corrective action program. 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 10CFR72.48.

On December 30, the inspectors performed a walk-down of the ISFSI storage pad with the auxiliary unit operator in order 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 (MPC) positioned on the ISFSI pad. The inspectors verified the MPC vents were in good condition and free of obstruction. The inspectors also verified that appropriate radiation surveys were being performed in the vicinity of 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 10CFR72.48. Documents reviewed are listed in the

.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

.1 Exit Meeting Summary

On January 7, 2015, the resident inspectors presented the inspection results to Mr. Carlin and other members of his staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-identified Violations

The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

Licensee Event Report (LER 2-2014-001-00) was submitted following the licensee's discovery that Sequoyah Unit 2 operated in a condition prohibited by Technical Specifications (TS). During mode 1 operation, train B containment purge had been operated without the minimum required operable radiation monitoring channels. TS Limiting Condition for Operation (LCO) 3.3.3.1 and TS LCO 3.3.2 required with less than the minimum channels operable, plant operation may continue provided the containment purge supply and exhaust valves are maintained closed. Contrary to the above during plant operations from April 8 and April 28, 2014, train B containment purge supply and exhaust valves were opened to place purge in service three times with containment

purge air exhaust radiation monitors (SQN-2-RM-090-130 and SQN-2-RM-090-131) being incorrectly aligned to train A purge. This was licensee identified and entered into the CAP as PER 878321. The finding was screened using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," Appendix A, The Significance Determination Process (SDP) For Findings At-Power, Exhibit 3 - Barrier Integrity Screening Questions and determined the finding to be of very low safety significance (Green) because it does not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components, or involve an actual reduction in function of hydrogen igniters.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Alfultis, Senior Manager of Projects

J. Carlin, Site Vice President

A. Day, Senior Manager of Chemistry

M. Halter, Senior Manager of Radiation Protection

D. Erb, Director of Work Control

J. Johnson, Program Manager Licensing

A. Little, Senior Manager of Nuclear Site Security

T. Marshall, Director of Nuclear Plant Operations

E. Henderson, Licensing Manager

M. Purcell, Senior Manager of Quality Assurance

E. Henderson, Director Plant Support (Acting)

W. Pierce, Site Engineering Director

M. Rasmussen, Director of Maintenance

P. Pratt, Plant Manager

K. Smith, Director of Training

NRC personnel

A. Hon, Project Manager, Office of Nuclear Reactor Regulation

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000328/2-2014-001-00 LER Misalignment of Containment Purge

Radiation Monitors Results in Condition

Prohibited by Technical Specifications (Section 4OA3 & 4OA7)

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

Section R01: Adverse Weather Protection

Procedures

0-PI-OPS-000-006.0, "Freeze Protection," Revision 58.

PERs

246247

953035

953044

956260

962457

Section R04: Equipment Alignment

Procedures

1/2-SO-3-2, Auxiliary Feedwater System 1/2-SO-3-2, Attachment 2, Auxiliary Feedwater System Valve Checklist

EA-3-2, Local Control of Turbine Driven AFW LCVs

EA-3.4. Local Alignment of TD AFW LCV Backup Air Supply

1/2-SI-SXV-000-201.0, Full Stroking of Category "A" and "B" Valves During Operation

0-SI-SXV-003-266.0, ASME Code Valve testing 0-TI-SXI-000-200.V, ASME OM Code Valve Testing 1/2-SI-SXP-003-201.A, Motor Driven Auxiliary F

eedwater Pump 1A-A (2A-A) Performance Test 1/2-SI-SXP-003-201.B, Motor Driven Auxiliary F

eedwater Pump 1B-B (2B-B) Performance Test 1/2-SI-SXP-003-201.S, Turbine Driven Auxiliary Feedwater Pump 1A-S(2A-S) Performance Test 1/2-SI-OPS-003-118.0, Auxiliary Feedwater Pump and Valve, Automatic Actuation

0-PI-SFT-067-005.A(B), ERCW 'A' ('B') Train System Flow Balance Using Hydraulic Monitoring 0-PI-OPS-067-003.0, ERCW System Flushing for Molluskicide Injection, Plant Inspections, and Post-Maintenance Testing

Work Orders

113014397

113592069

115253985

115883970

Attachment

PERs

782888

857326

897994

934076

Other documents

UFSAR Sec 10.4.7.2, Auxiliary Feedwater System Design Criteria,

SQN-DC-V-13.9.8, Auxiliary Feedwater Drawing 1,2-47W803-2, Flow Diagram Auxiliary Feedwater Drawing 1,2-47W803-3, Flow Diagram Auxiliary Feedwater

TS 3/4.7.1.2, Auxiliary Feedwater (AFW) System TS 3/4.3.3.2, Engineered Safety Feature Actuation System Instrumentation TS 3/4.3.3.5, Remote Shutdown Instrumentation

TS 3/4.3.3.7, Accident Monitoring Instrumentation

Section R05: Fire Protection

Procedures

SQN-FPR-Part-II, SQN Fire Protection Report Part II - Fire Protection Plan, Revision 33

Other documents

AUX-0-690-00, Fire Protection Pre-Fire Plans Auxiliary Building - El. 690, Revision 4

AUX-0-706-00, Fire Protection Pre-Fire Plans Auxiliary Building - El. 706, Revision 8

AUX-0-734-03, Fire Protection Pre-Fire Plans Auxiliary Building - El. 734 (U-X), Revision 8

AUX-0-749-01, Fire Protection Pre-Fire Plans Au xiliary Building - El. 749 (Unit 1), Revision 7

AUX-0-749-02, Fire Protection Pre-Fire Plans Au xiliary Building - El. 749 (Unit 2), Revision 8

AUX-0-749-01, Fire Protection Pre-Fire Plans Au xiliary Building - El. 759 (Unit 1), Revision 5

AUX-0-749-02, Fire Protection Pre-Fire Plans Au xiliary Building - El. 759 (Unit 2), Revision 5

1R07: Heat Sink Performance

Procedures

1-PI-SFT-070-001.0, Performance Testing of Component Cooling Heat Exchangers 1A1, 1A2, Revision 21

PERs

961330, Approximately 30 clam shell relics were found in the CS HTX 2A during performance of

WO 115775098

956687, 1A1/1A2 CCS Heat Exchangers need cleaned prior to summer 2015

Section R11: Licensed Operator Requalification Other documents

OPL273E1404 - 14-5 As-Found, Rev 1

Attachment Records: License Reactivation Packages (3 Records Reviewed) LORP Training Attendance records Medical Files (10 Records Reviewed)

Remedial Training Records (Various)

Remedial Training Examinations (10 Records Reviewed)

Various condition reports over the last two years related to licensed operator on shift performance Various closed condition reports that were simulator related

Written Examinations:

BRE RO A - R1 BRE SRO A - R1

Annual Examination Scenarios:

S-10, ATWS / MSLB Outside Containment, Rev. 1

S-97, LOCA with Loss of RHR Recirculation, Rev. 0 S-98A, SGTR - Failure of Auto Pressurizer Spray, Rev. 0

JPMs: RO ADMIN

0001360301 002, Perform System Operability Checklist, Rev. 1

RO 0390080101 003 - RO - IP - AP, Throttling Unit 1 Atmospheric Reliefs, Rev. 1

RO 3110160601 001 RO - SIM - AP, Respond to High Containment Pressure, Place RHR Spray in Service, Rev. 1 SRO ADMIN

5030010102 004 - SRO - ADMIN, Authorize a Radioactive Liquid Release, Rev.1 SRO ADMIN

3440190302 017 SRO - ADMIN, Classify the Event, Rev.1

RO 0000140504 001 - RO - IP, Local Alignment of U2 TDAFW LCV Back UP Air, Rev. 4

RO 0000680501 001- RO- IP - AP, Respond to Decreasing RCS Pressure from the Aux CR, Rev. 1

RO 0000380501 002 RO - SIM - AP, Isolate the Ruptured Steam Generator (With MSIV Failure

to Close), Rev. 1

RO 0280020201 002 - RO - SIM, Start Up 1B-B Hydrogen Recombiner, Rev. 1

RO 0640020101 002 - RO - SIM - AP, Perform D/G Load Test on 1B-B D/G (with ERCW Valve failure)

Procedures:

NPG-SPP-17.1, Systematic Approach to Training (SAT) Overview, Rev. 0010, (08/01/2014)

NPG-SPP-17.4.1 Exam Security and Exam Database Management, Rev. 0007 (06-07-2013)

NPG-SPP-17.8.1 Licensed Operator Requalification, Rev. 0011, (08-15-2014)

NPG-SPP-17.8.2 Job Performance Measures Development, Administration, and Evaluation, Rev. 0002, (04-04-2012)

NPG-SPP-17.8.3 Simulator Exercise Guide, Rev. 0004, (09-26-2013)

NPG-SPP-17.8.4 Conduct of Simulator Operations, Rev. 0001, (08-15-2014)

Simulator Static and Normal Tests:

0-GO-1 Unit Startup from Cold Shutdown to Hot Standby, Oct 7, 2014 0-GO-2 Unit Startup from Hot Standby to Reactor Critical, Oct 7, 2014

Attachment 0-GO-3 Power Ascension from Reactor Critical to Less than 5 Percent Power, Oct 7, 2014 0-GO-4 Power Ascension from Less Than 5% Power to 30% Power, Oct 7, 2014 0-GO-5 Normal Power Operation, Oct 7, 2014

Steady State Drift Test, Oct 7, 2014

Just in Time Training Simulator Scenarios:

OPL273SJITTMFP Place 1st MFP in Service JITT

OPL273SJITTPPT Reactor LPPT Startup JITT OPL273SJITTROLL Turbine Roll and Generator Synchronization 100%, 76%, 48% Steady State Static Tests, Oct 14, 2014

Simulator Transient Tests:

Transient Test 1, Manual Reactor Trip, Oct 20, 2014 Transient Test 2, Loss of Normal and Emergency Feed Water, Oct 20, 2014 Transient Test 3, Simultaneous Four Loop MSIV Closure, Oct 20, 2014

Transient Test 4, Simultaneous Four Loop Reactor Coolant Pump Trip, Oct 20, 2014

Transient Test 5, Single Loop Loss of Flow, Oct 20, 2014

Transient Test 6, Manual Turbine Trip Without Reactor Trip, Oct 20, 2014 Transient Test 7, Maximum Power Rate Ramp, Oct 20, 2014 Transient Test 8, Maximum Size LOCA with LOOP, Oct 20, 2014

Transient Test 9, Maximum Size Main Steam Line Break, Oct 20, 2014

Transient Test 10, Primary System Depressurization Using Pzr Relief Valve, Oct 20, 2014

Simulator Malfunction Tests (ANSI 3.5 1985 standard):

RH01 - RHR Pump Trips or Fails to Start,

Oct 13, 2014 ED10 - Loss of 120 VAC Inverter, Oct 9, 2014

RX07 - PZR Pressure Transmitter Fails High, Oct 13, 2014

RX18 - Failure of T-avg Control Signal, Oct 13, 2014

RP05 - False Automatic Reactor Trip Signal, Oct 13, 2014 RW07 - Loss of MFP Oil Cooling, Oct 13, 2014 FW23 - Main Feedwater Line Break Inside Containment, Oct 13, 2014

EG01 - Main Generator Trip, Oct 10, 2014

TH01 - Loss of Coolant Accident (LOCA) - Hot Leg, Oct 10, 2014

TH05 - Steam Generator Tube Leak, Oct 13, 2014

TU02 - Main Turbine Vibration, Oct 13, 2014

PERs: Closed PRs:

5679, 5674 through 5608, 5606 through 5599, 5596 through 5592, 5584, 5576,

5574, 5569, 5568, 5459, and 5453.

Ops Training PERs from Jan 1, 2013 - Nov 2014

Standards:

ANSI/ANS-3.5-1985, American National Standard Nuclear Power Plant Simulators for Use In Operator Training and Examination

ANSI/ANS-3.4-1983, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants

Attachment Corrective Action Documents

SR 963025, Insufficient simulator guide details

SR 963027, Exam security "near miss"

SR 963028, Inappropriate cueing observed during JPM performance

SR 963032, EAL overlap between simulator scenario and JPMs

SR 963372, Marking on meters not erased between JPMs

SR 963020, Two crews failed 12/2/14 LOR Annual Examination scenario Operator Reactivation under instruction (UI) not performed one on one as required by

OPDP-10, Appendix A (Return to Active Status Checklist)

Other documents

OPL273E1404 - 14-5 As-Found, Rev 1 Open Simulator Work Orders:

5593, 5597, 5598, 5607, 5675, 5676, 5677, and 5678

Section R12: Maintenance Effectiveness

Procedures

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

10CFR50.65, Revision 26

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

-

10CFR50.65, Revision 3

Other documents

CDE #2787 - 1B Charging Pump relay failure CDE #2798 - Shield Building Rad Monitor Failure

CDE #2799 - Trip of Vital Bus IV Battery Supply Section R13: Maintenance Risk Assessments and Emergent Work Evaluation

Procedures

NPG-SPP-07.1, On-Line Work Management, Revision 13

NPG-SPP-07.3, Work Activity Risk Management Process, Revision 16

NPG-SPP-09.11.1, Equipment Out of Service Management, Revision 10

Section R15: Operability Evaluations

PERs

PER 941069 - Station Blackout Air Cylinder (2-CYL-32-1950) pressure reading below 1500 psig

PER 904185, West Saddle Dike Failure

PER 926080, ERCW Pipe support failure

PER 952079 - FE for Boone Dam Sinkhole

PER 934663 - RHR valve failure during recirculation

Attachment Section R18: Plant Modifications Design Change Notices

DCN23197, "Installation of two Emergency 3MW Diesel Generators in the ADGB," Rev. A

Section R19: Post Maintenance Testing

Procedures

0-MI-MXX-030-001.0, Pulley Alignment and Belt Tensioning of ESF Coolers, Revision 11

Work Orders

115713757, 2B Centrifugal Charging Pump room cooler belt replacement & lube

115353846, Unit 1 Containment purge air supply fan A

Section R22: Surveillance Testing

Procedures

1-SI-SXP-062-202.B, Boric Acid Transfer Pump 1B-B Performance Test, Revision 17 0-SO-62-10, Boric Acid Batching, Transfer and Storage System, Revision 41

2-SI-SXP-070-201.A, Component Cooling Water pump 2A Section XI test, Revision 14

Work Orders

115672797, 1-SI-SXP-062-202.B Boric Acid Pump 1B Section XI Test

115684356, 2-SI-SXP-070-201.A CCS Pump 2A XI Test

Other documents

TVA Flow Diagrams 2-47W809-1, 47W809-2, 47W809-5, and 2-47W811-1

FSAR Section 9.3.4

Section 4OA2: Problem Identification and Resolution

Procedures

NPG-SPP-22.300, "Corrective Action Program," Revision 2

NPG-SPP-07.1, On-Line Work Management

OPDP-1, Conduct of Operations SQN ODM App O, Operations Guide to Daily Work Schedule, Schedule Review, and Intolerance Item Standards

Other documents Apparent Cause Evaluation for

PER 866924, "Non-Conforming IST Pump Tests" Maximo Report - NWM117, Open Work Orders with Focus Codes W1, W2 or W3, dated

2/8/2014

SQN Operations KPI Report on Operator Wo rkarounds (OWA) and Operator Burdens (OB), dated November 2014

Service Requests Residents reviewed all SRs issued between October 1, 2014 and December 31, 2014

Attachment

Section 4OA3: Event Followup

Procedures

0-SO-30-3, "Containment Purge System Operation"

0-SI-CEM-030-410.2, "Containment Upper and Lower Compartment Purge"

2-SO-90-2, "Gaseous Process Radiation Monitoring System"

EPIP-1, "Emergency Plan Classification Matrix"

PERs

878321

Other documents Licensee Event Report (LER)

2-2014-001-00, Misalignment of Containment Purge Radiation Monitors Results in Condition Prohibited by Technical Specifications TS LCO 3.3.3.1 & 3.3.2