ML17101A808

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NRC Team Inspection Report 05000280/2017009 and 05000281/2017009
ML17101A808
Person / Time
Site: Surry  Dominion icon.png
Issue date: 04/11/2017
From: Philip Mckenna
Reactor Projects Branch 7
To: Stoddard D
Virginia Electric & Power Co (VEPCO)
Philip J. McKenna
References
IR 2017009
Download: ML17101A808 (14)


See also: IR 05000280/2017009

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

April 11, 2017

David Stoddard, Senior Vice President

and Chief Nuclear Officer

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA 23060-6711

SUBJECT: SURRY POWER STATION - NRC TEAM INSPECTION REPORT

05000280/2017009 AND 05000281/2017009

Dear Mr. Stoddard:

On March 16, 2017, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Surry Power Station. The enclosed report documents the inspection results, which were

discussed with Mr. R. Simmons and other members of your staff on March 16, 2017.

The inspection examined activities conducted under your license as they relate to the

implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049

and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose

Assessment Plans, your compliance with the Commissions rules and regulations, and with the

conditions of your operating license. Within these areas, the inspection involved examination of

selected procedures and records, observation of Mr. Daniel G. activities, and interviews with

station personnel.

No NRC-identified or self-revealing findings were identified during this inspection.

D. Stoddard 2

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

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

system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Philip J. McKenna, Acting Chief

Reactor Projects Branch 7

Division of Reactor Projects

Docket No.: 50-280, 50-281

License No.: DPR-32, DPR-37

Enclosure:

IR 05000280/2017009, 05000281/2017009

w/Attachment: Supplemental Information

cc Distribution via ListServ

ML17101A808

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

NAME GMacDonald CJones AMasters SFreeman PMcKenna

DATE 04/03/2017 03/31/2017 04/10/2017 03/30/2017 04/11/2017

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No.: 50-280, 50-281

License No.: DPR-32, DPR-37

Report No.: 05000280/2017009, 05000281/2017009

Licensee: Virginia Electric and Power Company (VEPCO)

Facility: Surry Power Station, Units 1 and 2

Location: 5850 Hog Island Road

Surry, VA 23883

Dates: March 13 - 16, 2017

Inspectors: S. Freeman, Senior Reactor Analyst, RII (Team Leader)

G. MacDonald, Senior Reactor Analyst, RII

C. Jones, Resident Inspector, Surry

Approved by: Philip J. McKenna, Acting Chief

Reactor Projects Branch 7

Division of Reactor Projects

Enclosure

SUMMARY

IR 05000280/2017009, 05000281/2017009; 03/13/2017 - 03/16/2017; Surry Power Station

Units 1 and 2; Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation

Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness

Communication/Staffing/Multi-Unit Dose Assessment Plans issued December 23, 2015.

The inspection covered a one-week inspection by two senior reactor analysts and one resident

inspector. No NRC-identified or self-revealing findings were identified. The NRCs 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

None

REPORT DETAILS

4. Other Activities

4OA5 Other Activities (TI 2515/191)

The objective of Temporary Instruction (TI) 2015/191, Inspection of the Implementation

of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency

Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify

that licensees have adequately implemented the mitigation strategies as described in

the licensees Final Integrated Plan, which was described in letters dated

January 25, 2016, (ADAMS Accession No. ML 16033A353) and July 20, 2015,

(ADAMS Accession No. ML 15205A342) and the NRCs plant safety evaluation

(ADAMS Accession No. ML 16158A432) and to verify that the licensees installed

reliable water-level measurement instrumentation in their spent fuel pools. The

purpose of this TI is also to verify the licensees have implemented Emergency

Preparedness (EP) enhancements as described in their site-specific submittals and the

NRCs safety assessments, including multi-unit dose assessment capability and

enhancements to ensure that staffing is sufficient and communications can be

maintained during such an event.

The inspection verifies that plans for complying with NRC Orders EA-12-049, Order

Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-

Design-Basis External Events (ADAMS Accession No. ML12054A736) and EA-12-051,

Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation

(ADAMS Accession No. ML12054A679) are in place and are being implemented by

the licensee. Additionally, the inspection verifies implementation of staffing and

communications information provided in response to the March 12, 2012, request for

information letter and multiunit dose assessment information provided per COMSECY-

13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan

Lessons Learned, dated March 27, 2013, (ADAMS Accession No. ML12339A262).

The team discussed the plans and strategies with plant staff, reviewed documentation,

and where appropriate, performed plant walk downs to verify that the strategies could be

implemented as stated in the licensees submittals and the NRC staff prepared safety

evaluation. For most strategies, this included verification that the strategy was feasible,

procedures and/or guidance had been developed, training had been provided to plant

staff, and required equipment had been identified and staged. Specific details of the

teams inspection activities are described in the following sections.

1. Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

The team examined the licensees established guidelines and implementing

procedures for the beyond-design basis mitigation strategies. The team assessed

how the licensee coordinated and documented the interface/transition between

existing off-normal and emergency operating procedures with the newly developed

mitigation strategies. The team selected a number of mitigation strategies and

conducted plant walk downs with licensed operators and responsible plant staff to

assess: the adequacy and completeness of the procedures; familiarity of operators

4

with the procedure objectives and specific guidance; staging and compatibility of

equipment; and the practicality of the operator actions prescribed by the procedures,

consistent with the postulated scenarios. The team verified that a preventive

maintenance program had been established for the Diverse and Flexible Coping

Strategies (FLEX) portable equipment and that periodic equipment inventories were

in place and being conducted. Additionally, the team examined the introductory and

planned periodic/refresher training provided to the Operations and Security staff

most likely to be tasked with implementation of the FLEX mitigation strategies. The

team also reviewed the introductory and planned periodic training provided to the

Emergency Response Organization personnel. Documents reviewed are listed in

the attachment.

b. Assessment

Based on samples selected for review, the inspectors verified that the licensee

satisfactorily implemented appropriate elements of the FLEX strategy as described in

the plant specific submittals and the associated safety evaluation and determined

that the licensee was generally in compliance with NRC Order EA-12-049. The

inspectors verified that the licensee satisfactorily:

  • developed and issued FLEX Support Guidelines (FSG) to implement the

FLEX strategies for postulated external events.

  • integrated the FSGs into existing plant procedures such that entry into and

departure from the FSGs were clear when using existing plant procedures.

  • protected FLEX equipment from site-specific hazards.
  • developed and implemented adequate testing and maintenance of FLEX

equipment to ensure its availability and capability.

  • trained the staff to assure personnel proficiency in the mitigation of beyond-

design- basis events.

  • developed means to ensure that the necessary off-site FLEX equipment

would be available from off-site locations.

The inspectors verified that noncompliances with the current licensing

requirements, and other issues identified during the inspection, were entered into

the licensees corrective action program.

c. Findings

No findings identified.

2. Spent Fuel Pool Instrumentation

a. Inspection Scope

The team examined the licensees newly installed spent fuel pool instrumentation.

Specifically, the inspectors verified the sensors were installed as described in the

plant-specific submittals and the associated safety evaluation and that the cabling

for the power supplies and the indications for each channel were physically and

electrically separated. Additionally, environmental conditions and accessibility of

the instruments were evaluated. Documents reviewed are listed in the attachment.

5

b. Assessment

Based on samples selected for review, the inspectors determined that the licensee

satisfactorily installed and established control of the spent fuel pool (SFP)

instrumentation as described in the plant specific submittals and the associated safety

evaluation and determined that the licensee is generally in compliance with NRC Order

EA-12-051. The inspectors verified that the licensee satisfactorily:

  • installed the SFP instrumentation sensors, cabling and power supplies to provide

physical and electrical separation as described in the plant specific submittals and

safety evaluation.

  • installed the SFP instrumentation display in the location, environmental conditions

and accessibility as described in the plant specific submittals.

  • trained their staff to assure personnel proficiency with the maintenance, testing,

and use of the SFP instrumentation.

  • developed and issued procedures for maintenance, testing, and use of the reliable

SFP instrumentation.

The inspectors verified that noncompliances with the current licensing requirements,

and other issues identified during the inspection, were entered into the licensees

corrective action program.

c. Findings

No findings were identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walkdowns,

the team verified that the licensee had implemented required changes to staffing,

communications equipment and facilities to support a multi-unit extended loss of offsite

power scenario as described in the licensees staffing assessment and the NRC safety

assessment. The team also verified that the licensee had implemented dose

assessment (including releases from spent fuel pools) capability using the licensees

site-specific dose assessment software and approach as described in the licensees

multi-unit dose assessment submittal. Documents reviewed are listed in the

attachment.

b. Assessment

The inspectors reviewed information provided in the licensees multi-unit dose

submittal and in response to the NRCS March 12, 2012, request for information letter

and verified that the licensee satisfactorily implemented enhancements pertaining to

Near-Term Task Force Recommendation 9.3 response to a large scale natural

emergency event that resulted in an extended loss of all alternating current power

(ELAP) to the site and impedes access to the site. The inspectors verified the

following:

  • Licensee satisfactorily implemented required staffing change(s) to support an

ELAP scenario.

  • EP communications equipment and facilities were sufficient for dealing with an

ELAP scenario.

6

  • Implemented dose assessment capabilities (including releases from spent fuel

pools) using the licensees site-specific dose assessment software and approach.

The inspectors verified that noncompliances with the current licensing requirements,

and other issues identified during the inspection, were entered into the licensee's

corrective action program.

c. Findings

No findings identified.

4OA6 Exit

Exit Meeting Summary

On March 16, 2017, the inspectors presented the inspection results to

Mr. Roy Simmons and other members of the site staff. The inspectors confirmed that

proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel:

F. Mladen, Site Vice President

R. Simmons, Plant Manager

R. Johnson, Operations Manager

T. Shell, Assistant Operations Manager

H. Johnson, Superintendent of Shift Operations

J. Rosenberger, Site Engineering Director

J. Henderson, Manager of Design Engineering

J. Holloway, Engineering Supervisor

E. Turko, Engineering Supervisor

D Lawrence, Director of Nuclear Safety and Licensing

L. Baker, Manager of Nuclear Training

B. Garber, Licensing Manager

L. Helstosky, Licensing Engineer

D. Aitken, Licensing Engineer

A. Elms, FLEX Program Manager

K. Rowland, General Project Manager

NRC personnel:

E. Andrews, Acting Senior Resident Inspector

LIST OF REPORT ITEMS

Opened and Closed

None

Discussed

None

Attachment

LIST OF DOCUMENTS REVIEWED

Procedures

0-AP-10.15, Loss of the 428 / 469 Line (with 11 Attachments), Revision 29

0-OP-ZZ-021, Severe Weather Preparation, Revision 17

0-AP-37.01, Abnormal Environmental Conditions, Revision 69

0-ICP-FC-L-105-1, Spent Fuel Pool Level (1-FC-L-105-1) Calibration, Revision 4

0-ICP-FC-L-105-2, Spent Fuel Pool Level (1-FC-L-105-2) Calibration, Revision 5

0-NSP-ZZ-002, Inspection of FLEX Equipment, Revision 7

0-NSP-ZZ-003, Inventory of BDB FLEX Equipment, Revision 3

0-NSP-ZZ-004, Annual Testing of BDB Rapidcase Satellite Communications, Revision 1

0-MPM-1960-01, Semi-Annual or Annual Test of BDB Flex Equipment, Revision 6

0-MPM-1960-02, Annual Testing of BDB Support Equipment, Revision 1

0-MPM-1960-02, Annual Testing of BDB Support Equipment, Revision 2

0-FSG-5, Initial Assessment and Flex Equipment Staging, Revision 3

0-FSG-11, Alternate SFP Makeup and Cooling, Revision 2

1-AP-10.27, Loss of All AC Power While on RHR, Revision 2

1-AP-27.00, Loss of Decay Heat Removal Capability, Revision 27

1-ECA-0.0, Loss of All AC Power, Revision 41

1-FSG-1, Long Term RCS Inventory Control, Revision 1

1-FSG-2, Alternate AFW Suction Source, Revision 1

1-FSG-3, Alternate Low Pressure Feedwater, Revision 1

1-FSG-4, ELAP DC Bus Load Shed/Management, Revision 1

1-FSG-6, Alternate ECST Makeup, Revision 1

1-FSG-7, Loss of Vital Instrumentation or Control Power, Revision 0

1-FSG-8, Alternate RCS Boration, Revision 1

1-FSG-9, Low Decay Heat Temperature Control, Revision 0

1-FSG-10, SI Accumulator Isolation, Revision 0

1-FSG-12, Alternate Containment Cooling, Revision 0

1-FSG-13, Transition From FLEX Equipment, Revision 0

1-FSG-14, Shutdown RCS Makeup, Revision 1

1-FSG-15, 4160 VAC Generator Connection and Operation, Revision 0

2-AP-10.27, Loss of All AC Power While on RHR, Revision 0

2-AP-27.00, Loss of Decay Heat Removal Capability, Revision 27

2-ECA-0.0, Loss of All AC Power, Revision 40

2-FSG-1, Long Term RCS Inventory Control, Revision 1

2-FSG-2, Alternate AFW Suction Source, Revision 1

2-FSG-3, Alternate Low Pressure Feedwater, Revision 1

2-FSG-4, ELAP DC Load Shed/Management, Revision 0

2-FSG-6, Alternate ECST Makeup, Revision 1

2-FSG-7, Loss of Vital Instrumentation and Control Power, Revision 0

2-FSG-8, Alternate RCS Boration, Revision 1

2-FSG-9, Low Decay Heat Temperature Control, Revision 2

2-FSG-10, SI Accumulator Isolation, Revision 1

2-FSG-12, Alternate Containment Cooling, Revision 0

2-FSG-13, Transition From FLEX Equipment, Revision 0

2-FSG-14, Shutdown RCS Makeup, Revision 1

2-FSG-15, 4160 VAC Generator Connection and Operation, Revision 0

CM-AA-400, 10 CFR 50.59 and 10 CFR 72.48 - Changes, Tests, and Experiments, Revision 7

CM-AA-BDB-10, Beyond Design Basis FLEX Program, Revision 3

CM-AA-BDB-101, Beyond Design Basis FLEX Program Maintenance, Revision 5

CM-AA-BDB-102, Beyond Design Basis FLEX Equipment Unavailability Tracking, Revision 8

3

DNES-AA-GN-1003, Design Effects and Considerations, Revision 18EPIP-4.03, Dose

Assessment Team Controlling Procedure, Revision 18 Drawings

1301042-1-E-001, Master Diagram, Spent Fuel Pool Instrumentation, Surry Power Station -

Unit 1, Revision 1

11448-LP-1S14, Lighting Panelboard Schedule 01-EP-LP-1S14, Surry Power Station -

Unit 1, Revision 9

1301019-2-S-001, Installation/Fabrication Sketch Switchgear Receptacle Enclosure

2-BDB-DB-03, Surry Power Station - Unit 2, Revision 3

1301019-1-S-001, Installation/Fabrication Sketch Switchgear Receptacle Enclosure

2-BDB-DB-03, Surry Power Station - Unit 1, Revision 3

1301019-11448-FE-18HT, Wiring Diagram, BDB Receptacle Panel 01-BDB-DB-3, Surry Power

Station Unit - 1, Revision 3

1301019-11448-FE-13A, Wiring Diagram, Lighting Distribution, Surry Power Station Unit - 1,

Revision 2

1301019-11448-FE-18HR, BDB Distribution Panelboard Schedule 01-BDB-DB-1, Surry Power

Station Unit - 1, Revision 3

1301019-11448-FE-11D, Wiring Diagram Vital Bus Distribution Panels 1-IA & 1-IIIA, Surry Power

Station Unit - 1, Revision 2

1301019-11448-FE-11E, Wiring Diagram Vital Bus Distribution Panels 1-IIA & 1-IVA, Surry Power

Station - Unit 1, Revision 2

1301019-11448-FE-18HS, BDB Distribution Panelboard Schedule 01-BDB-DB-2, Surry Power

Station Unit - 1, Revision 2

1301019-11448-FE-11B, Wiring Diagram Vital Bus Distribution Panels 1-II & 1-IV, Surry Power

Station Unit - 1, Revision 2

1301019-11448-FE-11A, Wiring Diagram Vital Bus Distribution Panels 1-I & 1-III, Surry Power

Station Unit - 1, Revision 2

1301019-11448-FE-1L, 480V One Line Diagram, Surry Power Station Unit - 1, Revision 0

1301019-11448-FE-1M, 480V One Line Diagram, Surry Power Station Unit - 1, Revision 0

Modifications

Design Change SU-13-00015, BDB Storage Building, Surry Power Station, Units 1&2

Design Change Update 15-0002, BDB Storage Building, Surry Power Station, Units 1&2

Design Change SU-13-01042, Beyond Design Basis Spent Fuel Pool Level Instrument

Installations, Revision 12

Design Change Update SU-13-01042-007, Beyond Design Basis Spent Fuel Pool Level

Instrument Installation

Calculations

Breaker Coordination Curve for 120/240V BDB panels (Pages from Calculation EE-864)

Power Cable Details for DC-SU-13-01019, Cable Sizing and Voltage Drop, (Pages from

Calculation EE-864 Rev. 3 Attachment 13.2)

Condition Reports Reviewed

1019843 1055894 1054005 1041144 1042352 1029092 1015131

Condition Reports Generated as part of the Inspection

1062547, Unterminated Cable in U1 ECST Valve Vault

1062548, Review Cables in U2 ECST Valve Vault (Extent of Condition for CR1062547)

1062544, Drawing Error on Project Drawing 1301042-1-E-001

4

Work Orders

WO 38103535843, Loop Calibration on Support of DC SU-13-01042

WO 38103535844, Loop Calibration on Support of DC SU-13-01042

WO 38103707237, Perform Level Loop Calibration

WO 38103707242, Perform Level Loop Calibration

WO 38103693824, 00-BDB-P-2C-Unit FTPM: Perform Annual Test and Inspections, dated

April 6, 2016

WO 38103693856, 00-BDB-P-3A-Unit FTPM: Perform Annual Test and Inspections, dated

March 22, 2016

WO 38103693864, 00-BDB-P-3B-Unit FTPM: Perform Annual Test and Inspections, dated

March 22, 2016

WO 38103693856, 00-BDB-P-3A-Unit FTPM: Perform Annual Test and Inspections, dated

March 22, 2016

WO 38103693904, 00-BDB-GEN-2A-Unit FTPM: Perform Annual Test and Inspections, dated

April 4, 2016

WO 38103693912, 00-BDB-GEN-2B-Unit FTPM: Perform Annual Test and Inspections, dated

April 4, 2016

WO 38103693960, 00-BDB-GEN-1A-Unit FTPM: Perform Annual Test and Inspections, dated

April 4, 2016

WO 38103693976, 00-BDB-GEN-1C-Unit FTPM: Perform Annual Test and Inspections, dated

April 4, 2016

WO 38103693968, 00-BDB-GEN-1B-Unit FTPM: Perform Annual Test and Inspections, dated

April 4, 2016

WO 38103694016, 00-BDB-P-2B-Unit FTPM: Perform Annual Test and Inspections, dated

April 11, 2016

WO 38103694072, 00-BDB-P-1-Pump FTPM: Perform Annual Test and Inspections, dated

March 22, 2016

WO 38103694080, 01-FP-P-4-Pump FTPM: Perform Annual Test and Inspections, dated

March 22, 2016

WO 38103694128, 00-BDB-P-2A-Unit FTPM: Perform Annual Test and Inspections, dated

April 11, 2016

WO 38103694184, FTPM: Perform Annual Test and Inspections, dated June 10, 2016

WO 38103694192, 00-BDB-LF-1A-LIGHT FTPM: Perform Annual Test and Inspections, dated

June 10, 2016

WO 38103694200, 00-BDB-LF-1B-LIGHT FTPM: Perform Annual Test and Inspections, dated

June 10, 2016

WO 38103732208, 365 Day Freq. PT: Annual Testing of BDB Rapidcase Satellite

Communications, dated February 3, 2017

Other

Safety Evaluation Report - Surry Power Station Units 1 and 2 - Safety Evaluation Regarding

Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related

to Orders EA-12-049 and EA-12-051 CAC nos. MF1002, MF1003, MF1004, and MF1005 dated

August 4, 2016ETE-CPR-2012-0011, Beyond Design Basis - FLEX Strategy Basis Document

and Final Integrated Plan, Revision 7

ETE-CPR-2012-0011, Beyond Design Basis - FLEX Strategy Basis Document and Final

Integrated Plan, Revision 7, Attachment 1.

ETE-CPR-2014-1010, Surry Power Station BDB Flex Validation for Time Sensitive Actions,

Revision 1

ETE-CPR-2012-0011, Attachment 1, SPS Flex Strategy Basis Document 10.7.3 Development

Strategy BDB Fuel, Revision 7

ETE-CPR-2012-0011, Attachment 1, Section 7.2.11, Strategies for Repowering Remote

Monitoring Panel if Flooding of the ESGR Occurs, Revision 7

5

AREVA 51-9199717-015, National SAFER Response Center Equipment Technical

Requirements, Revision 15

Letter of Agreement, Commonwealth of Virginia, Department of Emergency Management, dated

August 15, 2016

NE-GL-0035S, PC-MIDAS Guideline, Rev. 9

NEI 12-01, Phase 2 Extended Loss of Alternating Current Power (ELAP) Emergency Response

Organization (ERO) Staffing Analysis Report, Revision 1

NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Rev B1

SU-15-01084, BDB Flood Barriers, Revision 2

Annual Test and Inspection 00-BDB-Gen-1C-Unit 120-240DG, BDB 40kW 120/240 VAC Diesel

Gen. 1C Preventive Work Order 38103693976 performed June 14, 2016

Annual Test and Inspection 00-BDB-Gen-1B-Unit 120-240DG, BDB 40kW 120/240 VAC Diesel

Gen. 1B Preventive Work Order 38103693968 performed June 14, 2016

Annual Test and Inspection 00-BDB-Gen-1A-Unit 120-240DG, BDB 40kW 120/240 VAC Diesel

Gen. 1A Preventive Work Order 38103693960 performed June 14, 2016

Annual Test and Inspection 00-BDB-Gen-2B-Unit 480V DG, Preventive Work Order 38103693912 performed June 15, 2016

Annual Test and Inspection 00-BDB-Gen-2A-Unit 480V DG, Preventive Work Order 38103693904 performed June 15, 2016

Simulator Scenario developed for ELAP demonstration dated March 17, 2017

Engineering Acceptance Test Procedure 0-NAT-E-003, Revision 2, Control Circuitry

Checkout/Initial Energization of Electrical Equipment, U2 BDB 120/240V Backfeed Test,

completed October 13, 2015

Engineering Acceptance Test Procedure 0-NAT-E-003, Revision 2, Control Circuitry

Checkout/Initial Energization of Electrical Equipment, U2 DBD 480V BDB Backfeed Test,

completed October 28, 2015

Engineering Acceptance Test Procedure 0-NAT-E-003, Revision 2, Control Circuitry

Checkout/Initial Energization of Electrical Equipment, U1 BDB 120/240V Backfeed Test,

completed May 16, 2015

Engineering Acceptance Test Procedure 0-NAT-E-003, Revision 2, Control Circuitry

Checkout/Initial Energization of Electrical Equipment, U1 DBD 480V BDB Backfeed Test,

completed May 16, 2015