The inspectors identified a non-cited violation of
10 CFR 50.34(b)(2) for failing to include in the
Updated Final Safety Analysis Report (
UFSAR) a description and analysis of the separate accelerated sequencer function that loads the safety-related equipment onto the safety-related emergency A.C. power system buses using different criteria than the committed sequencer function described in the
UFSAR. This issue is greater than minor because the failure to have a description of the accelerated sequencer function in the
UFSAR had a material impact on licensed activities, in that any modifications to safety-related systems, such as the modification that removed the seal-in function from the control room chiller digital control system, would need to consider the interaction with the accelerated sequencer (in addition to the separate committed load sequencer) to ensure that risk significant equipment, as modified, would function as analyzed. This issue was treated as traditional enforcement, because it had the potential for impacting the NRCs ability to perform its regulatory function. It was characterized as a
Severity Level IV violation, because the occurrence of the control room chiller failing to start(after being dropped by the accelerated load sequencer) when required by the committed load sequencer function during testing, had very low safety significance. This issue has a cross-cutting aspect of appropriate corrective action in the area of problem identification and resolution P.1.(d). This aspect was chosen because the licensee recognized, as documented in a January 12, 2007 letter to the NRC, that there were content problems with the
UFSAR and was in the process of trying to correct it. However, the inspectors could not find any completed interim corrective action documented in the licensees corrective action program that would alert/caution
UFSAR users that compensatory actions were needed in order to perform adequate evaluations such as for operability, reportability, or
10 CFR 50.59.The licensee intends to add the accelerated sequence function to the
UFSAR and install seal-in functions for the affected load blocks in the accelerated sequence