ML18340A172
| ML18340A172 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/06/2018 |
| From: | Omar Lopez-Santiago NRC/RGN-II |
| To: | Burchfield J Duke Energy Carolinas |
| References | |
| EA-18-036 IR 2018090 | |
| Download: ML18340A172 (21) | |
See also: IR 05000269/2018090
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
December 6, 2018
Mr. J. Ed Burchfield, Jr.
Site Vice President
Duke Energy Carolinas, LLC
Oconee Nuclear Station
7800 Rochester Highway
Seneca, SC 29672-0752
SUBJECT: OCONEE NUCLEAR STATION - NRC INSPECTION REPORT
05000269/2018090, 05000270/2018090, AND 05000287/2018090
Dear Mr. Burchfield:
This letter discusses a finding and non-cited violations of regulatory requirements identified
during the closure of unresolved item 05000269, 270, 287/2014007-05. The finding and
associated non-cited violations resulted from the failure to translate site design requirements
and licensing bases, specified in 10 CFR 50.55a(h), into design and implementation documents
used for plant modifications. Specifically, 10 CFR 50.55a(h) requirements specified in IEEE 279-1968 and IEEE 279-1971 were not translated into site modifications, thus subjecting
protection system components to multiple postulated hazard (IEEE 384-1992) from unanalyzed
single failures, which could damage protection system components preventing proper protective
actions at the system level when required. The modifications involved the Protected Service
Water (PSW) System addition implemented to meet 10 CFR 50.48(c), and modifications to
resolve existing vulnerabilities with tornados and high energy line breaks. Notwithstanding the
identified issues, the NRC recognizes that the intent of the PSW system and the modifications
related to tornados and high energy line breaks was to reduce the overall risk profile. The NRC
also recognizes that once these issues were identified by the inspectors, a number of
modifications were implemented to address the protection system single failure vulnerability
concerns associated with the subject plant modifications.
The unresolved item was initially identified in inspection report 05000269, 270, 287/2014007
(ADAMS Accession No. ML14178A535) during a component design basis inspection
conducted at your facility. Because of potential misinterpretations of the plant design and
licensing basis requirements for protection systems at Oconee and a clear sensitivity to the
potential for a backfit, the staff initiated a task interface agreement (TIA), 2014-05 (ADAMS
Accession No. ML16302A483) with the NRC Office of Nuclear Reactor Regulation (NRR) on
October 16, 2014. On August 5, 2015, the conclusions of the task interface agreement were
assessed and were confirmed by a peer review conducted by staff from the NRR, Division of
Engineering, Nuclear Regulatory Research, and other regional offices (ADAMS Accession No.
ML15216A621). On February 13, 2018, the NRC Committee to Review Generic Requirements
(CRGR) determined the TIA response did not contain backfitting or new staff positions as
J. Burchfield 2
documented in a CRGR memorandum (ADAMS Accession No. ML17289A542). On February
28, 2018, the TIA response confirmed that the modifications were implemented without full
consideration of plant design and license requirements for Class 1E protection systems.
The bases for the violations contained herein were informed by the NRC conclusion described
in the TIA referenced above. On March 12, 2018, staff from the NRC Region II office discussed
the preliminary results of this assessment with you and other members of your staff. The results
were documented in inspection report 05000269/2018013, 05000270/2018013, and
05000287/2018013 as apparent violations (AV) 05000269, 270, 287/2018013-01, Failure to
Translate Design and Licensing Basis Requirements and Verify Adequate Design, and AV
05000269, 270, 287/2018013-02, Failure to Submit for License Review and Obtain a License
Amendment for a Modification. On July 26, 2018, the results of the detailed risk evaluation
were discussed with you and other members of your staff. The enclosed report
05000269/2018090, 05000270/2018090, and 05000287/2018090 discusses a Severity Level IV
non-cited violation and a non-cited violation associated with a finding of very low safety
significance (Green). The NRC evaluated these violations in accordance Section 2.3.2.a of the
NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The NRC determined that these violations met the
criteria to be treated as non-cited violations.
If you contest the violations or significance of these NCVs, 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, DC 20555-0001; with
copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the
NRC resident inspector at the Oconee Nuclear Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Omar López-Santiago, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos. 50-269, 50-270, 50-287
License Nos. DPR-38, DPR-47, DPR-55
Enclosure:
Inspection Report 05000269/2018090,
05000270/2018090, and 05000287/2018090
w/Attachment: Supplementary Information,
(ADAMS Accession No. ML16302A483)
cc: Distribution via ListServ
ML18340A172 SUNSI REVIEW COMPLETE FORM 665 ATTACHED
RII DRP RII:DRS/EB1
OFFICE RII:DRS/EB1 RII:DRS/EB1 RII:DRS
SIGNATURE TNF1 ORL ATG MSF1 ORL
Non-Concur
NAME T. FANELLI O. LOPEZ- A. GODY S. FREEMAN O. LOPEZ-
NCP # 2018-006 SANTIAGO SANTIAGO
08/30/2018
DATE 9/ 13 /2018 11/ 13 /2018 12/06/2018 11/20/2018 12/ 06/2018
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Nos: 50-269, 50-270, and 50-287
License Nos: DPR-38, DPR-47, DPR-55
Report Nos: 05000269/2018090, 05000270/2018090, and 05000287/2018090
Enterprise Identifier: I-2018-090-0003
Licensee: Duke Energy Carolinas, LLC
Facility: Oconee Nuclear Station, Units 1, 2, and 3
Location: Seneca, SC 29672
Inspection Dates: March 7 - 12, 2018
Inspector: T. Fanelli, Senior Reactor Inspector
Approved By: Omar López- Santiago, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance
by conducting a follow up inspection of an unresolved item identified in inspection report
05000269, 270, 287/2014007 at Oconee Nuclear Station Units 1, 2, and 3, in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified
findings and violations are summarized in the tables below.
List of Findings and Violations
Failure to Translate Design and Licensing Basis Requirements and Verify Adequate Design
Cornerstone Significance Cross-cutting Report
Aspect Section
Initiating Events Green None 71111.21
NCV 05000269, 270, 287/2018090-01 Component
Closed Design Basis
Inspection
The NRC identified two examples of a Green finding and associated NCV of 10 CFR 50,
Appendix B, Criterion III, for the licensees failure to translate the site design requirements
specified in the site specific design and licensing basis into specifications used to design and
install modifications associated with the site protection systems1 and for the licensees failure
to verify that the same modifications met the design basis in the UFSAR2. Specifically, the
licensee exposed common Class 1E direct current (DC) system trains (power and control) for
the three Oconee units to potentially damaging high voltages by re-locating the common trains
adjacent to and parallel with the onsite alternating current (AC) power distribution system
cables. The configuration was not consistent with Oconees design requirements described in
IEEE 279-19683 and the single failure design requirements described in IEEE 279-19714.
Failure to Submit for License Review and Obtain a License Amendment for Modifications
Approval
Cornerstone Severity Cross-cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71111.21
NCV 05000269, 270, 287/2018090-02 Component
Closed Design Basis
Inspection
The NRC identified an NCV of Title 10 of the Code of Federal Regulations part 50.59(c)(2),
Changes, tests and experiments, for the failure to submit a plant modification for license
1
For purposes of the IEEE 279 criteria, the nuclear power generating station protection system encompasses all electric and
mechanical devices and circuitry (from sensors to actuation device input terminals) involved in generating those signals associated
with the protective function. These signals include those that actuate reactor trip and that, in the event of a serious reactor
accident, actuate engineered safeguards such as containment isolation, core spray, safety injection, pressure reduction, and air
cleaning. This IEEE 279 scope is considered to cover sensors and transducers, the devices that control actuators (control rods,
valves, pumps, etc.), and everything in between. In accordance with the Atomic Energy Commission (AEC) position in the 1968
publication from the Oak Ridge National Lab (ORNL) Nuclear Safety Information Center (NSIC), ORNL-NSIC-51, Design
Principles of Reactor Protection Instrument Systems. Section 2.1.
2
Updated Final Analysis Report (UFSAR) Oconee, Units 1, 2, and 3 Final Safety Analysis Report for Facility, dated 12/29/1970,
Volume 2. (ADAMS Accession No. ML12268A123)
3
IEEE 279-1968, Proposed IEEE Criteria for Nuclear Power Plant Protection Systems
4
IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations
3
review and obtain a license amendment for a change that resulted in more than a minimal
increase in the likelihood of occurrence of DC protection system malfunctions and a departure
from methods for protection system single failure analysis as described in the FSAR.
Specifically, the violation was associated with engineering changes (ECs), EC91880, Keowee
Emergency-start Cable, Revision 24, and EC91875, Keowee AC Power Supply Tie-Ins,
Revision 15, and EC91874, 13.8 KV Feed To PSW System from 100 KV APS, Rev. 7.
Additional Tracking Items
Failure to Translate Design and Licensing Basis Requirements and Verify Adequate Design
Cornerstone Significance Cross-cutting Report
Aspect Section
Initiating Events Apparent Violation None 71111.21
AV 05000269, 270, 287/2018013-01 Component
Closed Design Basis
EA-18-036 Inspection
Failure to Submit Changes for License Review and NRC Approval.
Cornerstone Significance/Severity Cross-cutting Report
Aspect Section
Initiating Events Apparent Violation None 71111.21
AV 05000269,270, 287/2018013-02 Component
Closed Design Basis
EA-18-036 Inspection
4
INSPECTION SCOPE
Inspections were conducted using the appropriate portions of the inspection procedure (IP) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. The team reviewed selected
procedures and records, observed activities, performed walk downs, and interviewed personnel
to assess licensee performance and compliance with Commission rules and regulations, license
conditions, site procedures, and standards.
REACTOR SAFETY
71111.21 - Component Design Bases Inspection (Team)
The team evaluated the following components, permanent modifications during the weeks of
February 10, 2014 to May 9, 2014 and March 9, 2018 to July 18, 2018.
Component (2 Samples)
(1) Keowee Emergency-start Logic
(2) 125 volt direct current (Vdc) Vital I&C Batteries (Units 1, 2, and 3)
Permanent Modification (3 Samples)
(1) Emergency Power Cable Replacement (Trench 3)
(2) Protected Service Water (PSW) Modifications
(3) Tornado / High Energy Line Break (HELB) Modification
5
INSPECTION RESULTS
Failure to Translate Design and Licensing Basis Requirements and Verify Adequate Design
Cornerstone Significance Cross-cutting Report
Aspect Section
Initiating Events Green None 71111.21
NCV 05000269, 270, 287/2018090-01 Component
Closed Design Basis
Inspection
The NRC identified two examples of a Green finding and associated NCV of 10 CFR 50,
Appendix B, Criterion III, for the licensees failure to translate the site design requirements
specified in the site specific design and licensing basis into specifications used to design and
install modifications associated with the site protection systems1 and for the licensees failure
to verify that the same modifications met the design basis in the UFSAR2. Specifically, the
licensee exposed common Class 1E direct current (DC) system trains (power and control) for
the three Oconee units to potentially damaging high voltages by re-locating the common trains
adjacent to and parallel with the onsite alternating current (AC) power distribution system
cables. The configuration was not consistent with Oconees design requirements described in
IEEE 279-19683 and the single failure design requirements described in IEEE 279-19714.
Description: This NCV was previously described as an Apparent Violation (AV) 05000269,
270, 287/2018013-01, Failure to Translate Design and Licensing Basis Requirements and
Verify Adequate Design, (EA-18-036) in inspection report 05000269/2018013,
05000270/2018013, and 05000287/2018013, and is further described below. Site
modifications installed the Protected Service Water (PSW) System which was implemented to
meet 10 CFR 50.48(c)5, and additional design changes were implemented that relocated
protection system cabling to mitigate vulnerabilities associated with tornados and high-energy
line breaks (HELBs). The team reviewed multiple design change packages for these
modifications to determine if the new designs maintained the original design and licensing
basis requirements. The team observed that the design changes interconnected new and old
cable raceway systems around the site together, that in effect, created one very long common
raceway with many branches to various parts of the Oconee power station. Design change
package NSM ON-530656,7 installed a raceway that connected the Oconee CT4 blockhouse to
the Keowee Hydro Station (Trench 3, 4000 feet), which is the onsite emergency underground
power source to the three Oconee units. The design change packages that installed the PSW
systems and tornado/HELB modifications (EC 91870, EC 91873, EC 91880, and EC 91881)8
1
For purposes of the IEEE 279 criteria, the nuclear power generating station protection system encompasses all electric and
mechanical devices and circuitry (from sensors to actuation device input terminals) involved in generating those signals associated
with the protective function. These signals include those that actuate reactor trip and that, in the event of a serious reactor
accident, actuate engineered safeguards such as containment isolation, core spray, safety injection, pressure reduction, and air
cleaning. This IEEE 279 scope is considered to cover sensors and transducers, the devices that control actuators (control rods,
valves, pumps, etc.), and everything in between. In accordance with the Atomic Energy Commission (AEC) position in the 1968
publication from the Oak Ridge National Lab (ORNL) Nuclear Safety Information Center (NSIC), ORNL-NSIC-51, Design
Principles of Reactor Protection Instrument Systems. Section 2.1.
2
Updated Final Analysis Report (UFSAR) Oconee, Units 1, 2, and 3 Final Safety Analysis Report for Facility, dated 12/29/1970,
Volume 2. (ADAMS Accession No. ML12268A123)
3
IEEE 279-1968, Proposed IEEE Criteria for Nuclear Power Plant Protection Systems
4
IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations
5
NRC issued Amendment Nos. 371, 373, and 372 to Renewed Facility Operating Licenses DPR-38, DPR-47, and DPR-55, for the
Oconee Nuclear Station, Units 1, 2, and 3, respectively (ML 103630612). The amendments consisted of changes to the licenses
and Technical Specifications (TSs) to allow you to maintain a fire protection program (FPP) in accordance with 10 CFR 50.48(c).
6
NSM ON-53065, Replace Underground Power, Aux. Power & Control Cables from Keowee to Oconee Nuclear Station, Rev. 1
7
K-0904-A Sections and Details Pre-Fab Concrete Trench #3, Rev. 0
8
Engineering Change (EC) 91870 PSW Building - This package installs the new PSW building which has been designed. This
building will house all the PSW equipment required for the PSW project. The PSW equipment will provide the electrical power for
6
installed a new raceway (PSW duct bank, 1800 feet) to connect to Trench 3 in order to
establish a raceway from the PSW system to the Keowee Hydro Station. In between the PSW
building and trench 3, the PSW duct bank intersected two original raceways that connected the
CT4 blockhouse to the switchyard (SY) relay house (SY trenches, 700 feet). Ultimately, the
design changes installed the cabling systems for the protection systems over the length of the
various raceways adjacent to high-voltage AC power that is capable of high power short circuit
currents. The cabling of concern included protection systems, Class 1E9 AC power and DC,
and non-Class 1E AC power and DC.
The Oconee UFSAR, since 1970, established in Chapter 7, that the protection systems shall
be designed to meet the intent of Standard IEEE-279. Additionally, prior to the issuance of
the provisional construction permit, the Oconee construction application10 specified that the
site protection systems would be designed and built in accordance with IEEE 279-1968. In
addition, in 1976 as part of the emergency core cooling system analysis to meet an NRC Order
associated with 10 CFR 50.4611, Oconee committed to the single failure requirements in
IEEE 279-197112. The team noted that these requirements were stated in Sections 4.2,
Single Failure Criterion, 4.7, Control and Protection System Interaction, 4.11, Channel
Bypass or Removal from Operation, and 4.17, Manual Initiation. From these requirements, it
was noted that the licensee failed to perform various analyses to verify the safety-related
functional performance and reliability of protection systems over the full range of electrical
transients and malfunctions expected due to the electrical design changes in modifications
NSM ON-53065, EC 91870, EC 91873, EC 91880, and EC 91881. As a result, the design
changes introduced multiple hazards from unanalyzed single failures.
The team reviewed the design specifications used for the design changes to determine if the
protection system design requirements were consistent with Oconees licensing bases as
required by 10 CFR 50.55a(h). The teams review determined that the licensee did not
implement the requirements of 10 CFR 50, Appendix B, Criterion III, as described in the
following examples.
the alternate feeds to the manual transfer switches.
EC 91873 PSW Power Feed Installation - This package installs the 600 VAC MCC in the Aux Building that provides the alternate
feed to the automatic transfer switches.
EC91880 Keowee Emergency-start Cable -this package used cables installed by NSM 53065 which originate in Keowee (KHU-1 &
KHU-2) and are terminated in the [CT4] Blockhouse termination cabinets (KHU-1A & KHU-2A). EC91880 installs new cables
from Blockhouse termination cabinets KHU-1A & KHU-2A to Aux Building via new PSW building and Keowee terminal cabinets
KHU-1B & KHU-2B located in the Unit 3 Aux Building 783 Elevation.
EC 91881 Ductbank - This package installs all the ductbank required for the PSW project cables.
9
Class 1E - The safety classification of the electric equipment and systems that are essential to emergency reactor shutdown,
containment isolation, reactor core cooling, and containment and reactor heat removal, or are otherwise essential in preventing
significant release of radioactive material to the environment. Note: For the purposes of this report, the terms Class 1E and
safety-related for electrical systems are interchangeable.
10
In Duke Power Company Amendment No. 1 to Application for Licenses Docket No s. 50-269 50-270 to the Oconee construction
application dated April 1, 1967 prior to the issuance of construction permits November 6, 1967, Oconee stated conformance to
the Proposed IEEE Criteria for Nuclear Power Plant Protection Systems, (ADAMS Accession No. ML 15215A125).
11
10 CFR 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclearpower reactors
Order for Modification of License for the Oconee Nuclear Power Station Units 1, 2, and 3 pertaining to your proposed Technical
Specifications which were submitted pursuant to Section 50.46 and Appendix K of 10 CFR Part 50. Dated 12/27/1974 (ADAMS
Accession No. ML 15216A221)
12
Response to Mr. R. A. Purple's request for additional information regarding the ECCS analysis for the Oconee Nuclear Station
Units 1, 2, and 3 dated 5/13/1976 (ADAMS Accession No. ML 16014A501)
7
Example 1:
The team determined that specification OSS-0254.00-00-4013, Design Basis Specification for
the Oconee Single Failure Criterion, failed to include design and licensing basis requirements
located in IEEE 279-1968 and IEEE 279-1971, and did not conform to statements in sections 7
and 8.2.3.3 of the Oconee UFSAR. Specifically, the team noted that design and analysis
requirements from IEEE 279, sections 3(g), 3(h), 4.2, and 4.7 were not translated into the
specification. The team also noted that design changes NSM ON-53065, EC 91870, EC 91873, EC 91880, and EC 91881 utilized the specification to perform design and analysis
related to the modifications.
The team noted the following sections in specification OSS-0254.00-00-4013 did not reflect the
original design requirements. The team noted that some of these sections were incorporated
by an internal memo to file13 written by Oconee dated 1993, which was not part of the site
licensing basis and was not reviewed by or approved by the NRC.
- Section 3.1.1, Single Failure, specified that single failures would only be considered
on demand of a component to operate;
- Section 3.2.1.3, Single Failure Licensing Basis for Electrical Systems, stated that the
Oconee design allows distinctions between active and passive electrical failures;
- Section 3.2.1.4.2, Single Failures in a System Shared by Two or More Units, excluded
the consideration of single failures from occurring during normal plant operations;
- Section 3.2.1.4.3, Effects of a Non-Qualified Component Failure, stated that Oconee
would not make any distinction between the protection systems and non-Class 1E
systems. Failures in the non-Class 1E systems were credited for the single failure
criterion, which does not meet the original design requirements for control system and
protection system interactions, and
- Section 3.3.6, Exemptions for Electrical Cabling and Internal Electrical Enclosure
Wiring, stated that Oconee would not consider single failures in armored electrical
cables, which did not meet the inclusion requirement in IEEE 279, Section 4.2 to
evaluate short-circuits in interconnected power cables.
The team further noted that Oconee design change package NSM ON-53065 updated the
UFSAR to include the bronze electrical shielding on power cables as armor, but the team
determined that the use of bronze shielding is not equivalent to armor and must be analyzed.
In response to the teams questions about including the effects of three phase short circuits on
the cable configurations in Oconee single failure analysis, the licensee specified14 that armor
makes this unnecessary. In addition, the licensee indicated that for high impedance grounded
systems such as the emergency power system, multiphase short circuits were not credible
because they required more than one single failure to make it possible. The team noted that
the Oconee electrical system is not high impedance grounded under all operating conditions.
In any event, three phase short circuits were credible in all of the Oconee electrical systems
and should have been considered in single failure analyses. The specification and the
13
Memo to File, ME Patrick (PJ North), dated 1/12/92, Single Failure Timing Licensing Basis, no file number given (Note: Memo was
actually written 1/12/93).
14
O-14-03190, corrective action document for Questions raised concerning single failure criteria associated with Keowee
underground cable (Trench 3), dated 03/27/2014.
8
licensees position on multiphase short circuits did not meet the original design requirements to
include in single failure analyses credible malfunctions or events that cause a number of
consequential component failures.
Example 2:
The team determined that specification OSS-218.00-00-0019, (ELECT) Installation Spec
Cable and Wiring Separation Criteria, failed to include design and licensing basis
requirements located in IEEE 279-1968 and IEEE 279-1971. Specifically, design and analysis
requirements from IEEE 279, sections 3(g), 3(h), 4.5, and 4.6 were not translated into the
specification, and design changes NSM ON-53065, EC 91870, EC 91873, EC 91880, and EC 91881 utilized the specification to perform design and analysis related to the modifications.
The team noted the following sections in specification OSS-218.00-00-0019 which did not
reflect the original design requirements and led to deficiencies in the modifications designs.
- Section 4.1 defined that cable armor although providing substantial protection is not
considered a barrier to provide isolation, moreover the specification did not provide
any criteria to verify barrier material for proper isolation. Barriers would need to be
matched to the power levels they are exposed to so they would not be defeated directly
or indirectly. Due to the use of this specification during development of their
modification packages, the licensee failed to perform analyses to determine if the
interlinked armor cable and bronze shielding materials they credited for independence
and separation were qualified as barriers for the high power levels; and
- Section 6.4 specified that trenches may simultaneously contain power, control and
instrumentation cables. Mutually redundant safety cables shall be located on
opposite sides of the trench. The specification did not have any provisions for
separation distance in trenches other than one quarter the diameter of the larger power
cable. This distance cannot provide proper isolation for high power transients. The
team observed that the design changes exposed the protection systems and Class 1E
DC power systems to potential interactions between Class 1E and Non-Class 1E AC
Power systems, which could adversely affect the reliability of the protection systems.
Specifically, the licensee did not analyze that the design could maintain necessary
functional capability under extremes conditions from voltage impressment and
induction events that could disable the functional capability of the protection systems.
The team determined that the licensees failure to verify through analyses that the design
changes met the site protection system design requirements introduced unanalyzed single-
failure hazards that could degrade the integrity of the protection systems.
Corrective Actions: The licensee implemented a number of modifications to address the
protection system single failure vulnerability concerns associated with the subject plant
modifications. On February 28, 2018, (ML180051B257) the NRC granted relief from the
applicable Code and concluded that the proposed alternatives provided an acceptable level of
quality and safety for the specified cable configurations and locations. The NRC plans to
conduct inspections of the corrective actions for the aforementioned violation, as appropriate.
Corrective Action Reference: AR 02203327 and NCRs 1864405, 1905999, and 1906088.
9
Performance Assessment:
Performance Deficiency: The licensee exposed common Class 1E DC system trains (power
and control) for the three Oconee units to potentially damaging high voltages due to postulated
failures by re-locating the common trains adjacent to and parallel with the onsite AC power
distribution system cables. The configuration did not comply with the Oconee design and
licensing basis identified in IEEE 279-1968 and IEEE 279-1971 and thus was a performance
deficiency and violation of 10 CFR 50, Appendix B, Criterion III (NCV 05000269, 270, &
287/201890-01).
Screening: The performance deficiency was determined to be more than minor because it was
associated with the Design Control attribute of the Initiating Events Cornerstone and adversely
affected the cornerstone objective of limiting the likelihood of events that upset plant stability
and challenge critical safety functions. Specifically, the failure to translate the design
requirements of IEEE 279-1968 and IEEE 279-1971 into specifications resulted in cable
alignments that could let high-current electrical failures cause induced high-voltages and
impressed voltages on the protection systems. This created the possibility for a new accident
sequence.
Significance: The team evaluated the finding with Inspection Manual Chapter (IMC) 0609, Att.
4, Initial Characterization of Findings, issued October 7, 2016, for Initiating Events, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power,
issued June 19, 2012, and determined the finding met the Support System Initiators screening
criteria for requiring a detailed risk evaluation. The team determined that this issue increased
the likelihood of the support system initiator site wide loss of offsite power (LOOP) in addition
to the site wide loss of DC protection systems. A regional Senior Reactor Analyst (SRA)
performed the detailed risk evaluation using input from SAPHIRE Version 8.1.7 and Versions
8.50 and 8.55 of the SPAR Model for Oconee. The SRA developed a new event tree to model
the various cable segments and damage states for the finding. The result was an increase in
core damage frequency of less than 1E-6/year for each Oconee unit, which would be a finding
of very low significance (Green). The dominant sequence was related to a fault in the normally
energized 4.16 kVac cable in the new Trench 3 from Keowee to Oconee that resulted in a total
loss of AC & DC power. This was mitigated by the standby shutdown facility and the low
likelihood of a fault severe enough to cause damage or the low probability of such a severe
damage state. No cross cutting aspect was assigned to this finding because the inspectors
determined the finding did not reflect present licensee performance.
Enforcement: 10 CFR Part 50, Appendix B, Criterion III, Design Control, stated, in part, that
measures shall be established to assure that applicable regulatory requirements and the
design basis, as defined in § 50.2 and as specified in the license application, for those
structures, systems, and components to which this appendix applies are correctly translated
into specifications, drawings, procedures, and instructions, that design control measures
shall provide for verifying or checking the adequacy of design, and that design changes,
including field changes, shall be subject to design control measures commensurate with those
applied to the original design The Oconee regulatory requirements and the design basis for
the design of protection systems are, in part, IEEE 279-1968, Section 1, Scope, Section 2,
Definitions, Section 3, Design Basis, and Section 4, Requirements, and IEEE 279-1971
Sections 4.2, Single Failure Criterion, Section 4.7, Control and Protection System
Interaction, Section 4.11, Channel Bypass or Removal from Operation, and Section 4.17,
Manual Initiation.
10
Contrary to the above, the NRC identified examples of the licensee failing to meet the
aforementioned requirements from May 17, 2001 to May 9, 2014, when the licensee approved
multiple modification packages associated primarily with protected service water system
modifications. The licensee failed to ensure the regulatory requirements and design basis
requirements were translated into specifications, drawings, procedures, and instructions and
failed to apply design control measures commensurate with the original design. The
modification packages involved the installation of Class 1E and non-Class 1E AC power and
DC cabling systems adjacent to one another over long distances in the PSW duct bank, SY
trenches, and Trench 3.
The licensee failed to translate the original design requirements from IEEE 279-1968 and IEEE 279-1971 into specifications OSS-0254.00-00-4013, Design Basis Specification for the
Oconee Single Failure Criterion, and OSS-218.00-00-0019, Installation Spec Cable and
Wiring Separation Criteria,; failed to translate those requirements into the modification
packages instructions and procedures; and failed to verify the adequacy of the design as
compared to those requirements in their modification design packages.
Specifically:
The licensees use of specification OSS-0254.00-00-4013, Design Basis Specification for the
Oconee Single Failure Criterion, Revision 4, failed to ensure that the protection system single
failure analyses for the subject modifications was properly conducted. Specific design bases
not in the specification included: IEEE 279-1968, Section 3, which required analysis
throughout the full range of normal conditions, transient conditions, and malfunctions specified
in the electrical systems design basis; IEEE 279-1971, Section 4.2 , which required an
analysis of passive and active single failures occurring within the protection system at any
time; and IEEE 279-1971, Section 4.7 , which required an analysis of failures that could occur
within the protection system in addition to any non-Class 1E equipment failures that could
degrade the protection system.
The licensees use of specification OSS-218.00-00-0019, Installation Specification for Cable
and Wiring Separation Criteria, Revision 17, failed to ensure the protection system electrical
channel integrity and channel independence for the subject modifications. Specific design
bases not included in the specification included: IEEE 279-1968, Section 3, which required an
analyses of the protection system throughout the full range of normal conditions, transient
conditions, and malfunctions; IEEE 279-1968, Section 4.5, which required the protection
system channels to maintain necessary functional capability under extremes of conditions; and
IEEE 279-1968, Section 4.6, which required the protection system to be independent and
physically separated from the coupling effects (e.g. voltage induction and impressment)
resulting from unsafe electrical faults (transients). Of note was that while OSS-218.00-00-
0019, Section 4.1, did state that cable armor although providing substantial protection is not
considered a barrier to provide isolation, it did not result in the required analyses.
The failure to verify the adequacy of the multiple modification packages combined with the
failure to translate the design requirements of IEEE 279-1968 and IEEE 279-1971 into plant
specifications resulted in the introduction of multiple unanalyzed conditions where an electrical
fault in a power system cable could potentially result in damage to the protection systems
which could prevent proper protective actions at the system level.
11
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance
(GREEN) and was entered into the licensees corrective action program as AR 02203327.
Failure to Submit Changes for License Review and NRC Approval.
Cornerstone Severity Cross-cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71111.21
NCV 05000269, 270, 287/2018090-02 Component
Closed Design Basis
Inspection
The team identified an NCV of 10 CFR 50.59(c)(2), Changes, tests and experiments, for the
failure to submit a plant modification for license review and obtain a license amendment for a
change that resulted in more than a minimal increase in the likelihood of occurrence of DC
protection system malfunctions and a departure from methods for protection system single
failure analysis as described in the FSAR. Specifically, the violation was associated with
engineering changes (ECs), EC91880, Keowee Emergency-start Cable, Revision 24 and
EC91875, Keowee AC Power Supply Tie-Ins, Revision 15, and EC91874, 13.8 KV Feed To
PSW System from 100 KV APS, Rev. 7.
Description: This NCV was previously described as an Apparent Violation (AV) 05000269,
270, 287/2018013-02, Failure to Submit for License Review and Obtain a License
Amendment for a Modification, (EA-18-036) in inspection report 05000269/2018013,
05000270/2018013, and 05000287/2018013, and is further described below. The licensees
procedure for evaluating changes under 10 CFR 50.59, NSD 2091 utilized the guidance in NEI
96-072. Section 4.3.2, of NEI 96-07 specified that if a change in likelihood of occurrence of a
malfunction increases by more than a factor of two the modification would need NRC approval,
because certain changes that satisfy the factor of two limit exceed the minimal increase
standard for accident/transient frequency under criterion 10 CFR 50.59(c)(2)(i). The team
evaluated the change in likelihood of malfunctions in the DC protection systems3. The
changes in question installed protection system cables adjacent to medium voltage high power
AC cables in multiple areas, which did not meet the site licensing basis for 10 CFR 50.55a(h)
and the specific requirements of the IEEE 279 standards.
The following is a description of the modifications in question:
1
Nuclear System Directive (NSD): 209 10 CFR 50.59 Process,
2
Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1
3
For purposes of the IEEE 279 criteria, the nuclear power generating station protection system encompasses all electric and
mechanical devices and circuitry (from sensors to actuation device input terminals) involved in generating those signals associated
with the protective function. These signals include those that actuate reactor trip and that, in the event of a serious reactor
accident, actuate engineered safeguards such as containment isolation, core spray, safety injection, pressure reduction, and air
cleaning. This IEEE 279 scope is considered to cover sensors and transducers, the devices that control actuators (control rods,
valves, pumps, etc.), and everything in between. In accordance with the Atomic Energy Commission (AEC) position in the 1968
publication from the Oak Ridge National Lab (ORNL) Nuclear Safety Information Center (NSIC), ORNL-NSIC-51, Design
Principles of Reactor Protection Instrument Systems. Section 2.1.
12
The first modification was implemented from 2000 to 2002. Oconee replaced the Keowee
power cabling system to address aging degradation. Change package NSM ON-530654,5
replaced two independent, previously separately direct buried, cabling systems with new
cabling systems routed in a new underground concrete raceway designated as Trench 3.
The raceway was a 2.4 foot by 2.75 foot concrete tunnel 4000 feet long between the Oconee
CT4 (transformer) blockhouse and the Keowee Hydro Station. Following the modification
installation, a barrier between the two cabling systems no longer existed, as there was when
they were separately buried. The two new cabling systems included twelve 13.8 kilo-volt (kV)
and six 4.16 kV AC power cables and 24 multi-conductor DC protection system cables. The
DC protection system cables were installed parallel to the AC power cables along the length of
Trench 3 within five inches. This modification placed into service six of the 13.8 kV cables and
three 4.16 kV cables. The portion of the unused AC power cables that were longer than the
Trench 3 raceway were left uncut on reels in the switchyard (spared) for future use. The DC
cables were connected to terminal cabinets at Oconee (CT4 blockhouse) and at the Keowee
Hydro Station and left unconnected to the protection systems for use in future modifications.
This modification did not present hazards until the modifications were completed in 2014.
The second series of modifications were implemented from approximately 2007 to 2014.
Engineering change packages implemented design changes to address the fire, tornado, and
HELB vulnerabilities in the turbine building (EC 91870, EC 91873, EC 91880, and EC 918816).
The modifications added approximately 1800 feet of cabling systems outside in an
underground duct bank raceway to bypass the turbine building. The raceway interconnected
with two outside switchyard (SY) trenches leading to the CT4 blockhouse. The raceway then
went on to provide an outside route to Keowee through Trench 3. Approximately 24 safety-
related DC cables and three PSW non-safety-related DC cables were routed in the raceways
within inches in parallel with the non-safety-related PSW high power AC cabling systems and
with the Keowee Class 1E high power emergency power AC cabling systems. For the PSW to
Keowee route, six of the spare 13.8kV cables from the previous modification were used. The
cables provided two trains of non-Class 1E power from the Keowee Hydro Station to the PSW
building (approximately 5800 feet). Six additional new 13.8kV cables provided two normal
trains of non-Class 1E power from an offsite commercial power source (approximately 400 feet
from the duct bank manhole six to the PSW building). The SY trenches contained non-safety-
related 4.16kV AC power cables to provide AC power to the switchyard. The cables for the
switchyard isolation protection system, which are part of the safety-related DC cables, returned
to the switchyard relay house through the SY trenches (approximately 700 feet).
The alignment of cabling in raceway systems introduced multiple postulated hazards from
unanalyzed single failures. The hazards created the possibility for a new accident sequence.
The accident sequence could result from high voltages developed between the AC power
systems and the DC (protection and power) systems. The voltages could result from faulted
conditions in the interconnected AC power components. These single failure vulnerabilities
could credibly disable the AC systems, and may prevent proper protection system actuation
when the systems are required to operate. The design is contrary to the requirements of IEEE Std. 279 and the Oconee licensing basis.
The team used the SPAR model and IEEE 493-20077 to estimate whether the increase in
likelihood of failure of DC system components exceeded the factor of two threshold
established in NEI 96-072. The IEEE standard met the requirements of 10 CFR 50.54(jj) for
consideration in protection system design. The standards failure frequency database included
the necessary components (e.g. cables, switchgear, switchgear, terminations, circuit breakers,
13
and transformers). The standard deconstructed the component failures to the damaged part
and failure type, the failure repair method, and repair urgency (i.e. how catastrophic the failure
was). These characteristics were used to estimate the number of faults that could induce
damaging voltages in the DC protection systems. The SPAR model provided a nominal
random failure rate for each of the DC protection system buses of 1.9 E-3 per year. The buses
in this configuration have the potential to fail from the same event. The standards database
gave a random nominal failure rate for the power cable in the raceways. The cable was
metallically shielded thermoset AC medium voltage cable. The failure rate was approximately
8.89 E-3 failures per thousand feet per year. Given a total length of cable in Trench 3 of
10260 feet, and the proximity and parallel length of cables, the estimated increase in likelihood
of a DC system malfunction exceeded the factor of two threshold established in NEI 96-072.
Additionally, the guidance in NEI 96-07, Section 4.3.8, specified that the use of new or different
methods of evaluation that are not approved by NRC for the intended application required
NRC approval. The methods used were not consistent with the methods described in the
Oconee licensing basis. The UFSAR, Chapter 7, described the single failure analysis
methodology:
No single component failure will prevent a protective system from fulfilling its protective
functions when action is required, and
No single component failure will initiate unnecessary protective system action where
implementation does not conflict with the criterion above.
The licensee developed new single failure timing criteria around 1993 in a memo to file8. The
timing excluded credible single failures that occurred at any other time than on demand. The
licensee incorporated the new timing criteria in a design basis specification (DBD) for single
failures9 created in 1995. Using the guidance from the single failure DBD, the licensee
excluded single failure vulnerabilities that could have prevented the protection system from
fulfilling its protective functions when action was required.
The UFSAR, Section 8.3.1.2, Analysis, for onsite AC Power Systems stated that the basic
design criterion for the electrical portion of the emergency electric power system of a nuclear
unit, including the generating sources, distribution system, and controls is that a single failure
of any component, passive or active, will not preclude the system from supplying emergency
power when required. The single failure DBD, Section 3.2.1.3 specified, In 10 CFR 50
Appendix A, there is no distinction between active and passive failures in electrical systems.
However, the criteria in 10 CFR 50 Appendix A are not part of Oconees licensing basis, and a
4
NSM ON-53065, Replace Underground Power, Aux. Power & Control Cables from Keowee to Oconee Nuclear Station, Rev. 1
5
K-0904-A Sections and Details Pre-Fab Concrete Trench #3, Rev. 0
6
- Engineering Change (EC) 91870 PSW Building - This package installs the new PSW building, which has been designed. This
building will house all the PSW equipment required for the PSW project. The PSW equipment will provide the electrical power
for the alternate feeds to the manual transfer switches.
EC 91873 PSW Power Feed Installation - This package installs the 600 VAC MCC in the Aux Building that provides the alternate
feed to the automatic transfer switches.
EC91880 Keowee Emergency-start Cable -this package used cables installed by NSM 53065 which originate in Keowee (KHU-1
& KHU-2) and are terminated in the [CT4] Blockhouse termination cabinets (KHU-1A & KHU-2A). EC91880 installs new cables
from Blockhouse termination cabinets KHU-1A & KHU-2A to Aux Building via new PSW building and Keowee terminal cabinets
KHU-1B & KHU-2B located in the Unit 3 Aux Building 783 Elevation.
EC 91881 Ductbank - This package installs all the ductbank required for the PSW project cables.
7
IEEE 493-2007, IEEE Recommended Practice for the Design of Reliable Industrial and Commercial Power Systems,
8
Memo to File, ME Patrick (PJ North), dated 1/12/92, Single Failure Timing Licensing Basis, no file number given (Note: Memo was
actually written 1/12/93).
9
OSS-0254.00-00-4013, Design Basis Specification for the Oconee Single Failure Criterion, Rev. 4
14
distinction between active and passive failures is made for Oconee electrical systems (see
Reference 4.3.1.1). Reference 4.3.1.1 is the memo from 19938. Using the guidance in the
single failure DBD, the licensee excluded passive single failures that could have prevented the
protection system from fulfilling its protective functions when action is required.
The team determined that these changes were a change to methods of evaluation described in
the UFSAR and would need NRC approval, because it was considered a departure from a
method of evaluation described in the UFSAR.
From the time this issue was first identified, the licensee performed several modifications
designed to remove the DC protection system cables from the parallel configurations in
question. In addition, the site was granted relief (ADAMS Accession No. ML18060A028) for
certain areas where the licensee found corrective action too problematic in accordance with 10 CFR 50.55a(z). However, the SY trenches were not included in the relief request, and the two
SY trenches each contained one channel of the DC protection system cables in parallel with
medium voltage cables. As such, the corrective action in this area would need to be
addressed.
Corrective Actions: The licensee implemented a number of modifications to address the
protection system single failure vulnerability concerns associated with the subject plant
modifications. On February 28, 2018, (ML180051B257) the NRC granted relief from the
applicable Code and concluded that the proposed alternatives provided an acceptable level of
quality and safety for the specified cable configurations and locations. The NRC plans to
conduct inspections of the corrective actions for the aforementioned violation, as appropriate.
Corrective Action References: AR 02203327 and NCRs 1864405, 1905999, and 1906088
Performance Assessment:
Traditional Enforcement Assessment: This violation was associated with a previously
documented finding assessed using the significance determination process, which was
documented under NCV 05000269, 270, 287/2018090-01.
Enforcement:
Severity: The ROP significance determination process does not specifically consider the
regulatory process impact in its assessment of licensee performance. Therefore, it is
necessary to address this violation, which impedes the NRCs ability to regulate using
traditional enforcement to adequately characterize the non-compliance. The finding was
determined to be a Severity Level IV violation consistent with Section 6.1.d.2 of the NRC
Violation: 10 CFR 50.59(c)(2), Changes, tests and experiments, required, in part, a licensee
shall obtain a license amendment pursuant to Sec. 50.90 prior to implementing a change, test,
or experiment if the change, test, or experiment would (ii) result in more than a minimal
increase in the likelihood of occurrence of a malfunction of a structure, system, or component
(SSC) important to safety or (viii) result in a departure from a method of evaluation described
in the FSAR (as updated) used in establishing the design bases, or in the safety analyses.
Contrary to the above, from June 2013 until discovery, the licensee failed to obtain a license
amendment pursuant to Sec. 50.90 prior to implementing a change that resulted in more than
a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to
15
safety previously evaluated in the FSAR and departed from a method of evaluation described
in the FSAR (as updated) used in establishing the design bases or in the safety analyses.
Specifically, the licensee implemented modifications to the plant that resulted in a more than
minimal increase in the likelihood of occurrence of a malfunction of the DC protection systems
that had the potential to adversely affect the three Oconee units and the Keowee emergency
power hydro station, and departed from the single failure analysis methods decribed in the
FSAR.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2.a of the Enforcement Policy, because it was very low safety significance (SLIV)
and was entered into the licensees corrective action program as AR 02203327.
EXIT MEETINGS AND DEBRIEFS
On July 26, 2018, the NRC presented the results of the detailed risk evaluation to you and other
members of your staff.
LIST OF DOCUMENTS REVIEWED
CALCULATIONS
KC-2190-004 Failure Mode and Effects Analysis (FMEA) for the Keowee 13.8 KV Switchgear
(KPF) Power Feeds To Protected Service Water System (PSW) Switchgear (B6T B7T)
KC-2195-000, Keowee 13.8 KV Breaker Equipment Mounting and Cable Tray Supports
Qualification
KC-2197-001, Keowee Hydro KPF-1 and KPF-2 13.8KV Switchgear Arc-Flash Analysis 6
16 2011
OSC-7729-003, Oconee-Keowee Underground Power Cable Replacement Calculations (for
NSM ON-53065), Rev. 3
OSC-9370, Units 123 PSW AC Power System Voltage and Short Circuit Analysis
KC-2217, Protective Relay Settings for Keowee 13.8 kV KPF Switchgear Rev. 2
OSC-9831, Protective Relay Settings Associated with PSW Switchgear Rev. 3
KC-2131, Electrical Design Input Calculation for NSM ON-53065 (Keowee Underground Cable
Replacement)
OSC-7729, Oconee-Keowee Underground Power Cables Replacement Calculations Rev. 3
OSC-5096, Keowee Single Failure Analysis, Rev. 13
OSC-3716 Station Blackout Coping Study Rev. 001
OSC-2059, U1 AC Power System Voltage and Fault Duty Analyses, Rev. 25
DRAWINGS
O-711-C, Unit 1 Connection Diagram Unit Control Board 1UB1, Rev. 68
O-1711-C, Unit 2 Connection Diagram Unit Control Board 2UB1, Rev. 64
O-2711-D, Unit 2 Connection Diagram Unit Control Board 3UB1, Rev. 56
O-705, Unit 1 One Line Diagram 120 VAC & 125 VDC Station Aux. Circuits Instrumentation
Vital Buses, Rev. 98
O-1705, Unit 2 One Line Diagram 120 VAC & 125 VDC Station Aux. Circuits Instrumentation
Vital Buses, Rev. 82
O-2705, Unit 3 One Line Diagram 120 VAC & 125 VDC Station Aux. Circuits Instrumentation
Vital Buses, Rev. 80
O-753-L, Connection Diagram Keowee Emergency-start Panel - Rev. 17G
O-1753-N - Connection Diagram Keowee Emergency-start Panel - Rev. 9B
O-2753-N - Connection Diagram Keowee Emergency-start Panel - Rev. 12B
K-904-B Sections and Details Trench #3 Power Cable Switchover, Rev. 0
KEE 117, Elementary Diagram Remote Controls, Rev. 6
KEE 217 Elementary Diagram Remote Controls KHU2, Rev. 8
KEE-213 KHU2 Master control Start, Rev. 25
OEE 120, Elementary Diagram Channel A Keowee Emergency-start, Rev. 17
OEE 120-A, Elementary Diagram Channel A Keowee Emergency-start Contact Development,
Rev. 10
OEE 120-I, Elementary Diagram Channel B Keowee Emergency-start, Rev. 17
OEE 120-A-I, Elementary Diagram Channel B Keowee Emergency-start Contact Development,
Rev. 10
O-799-A Interconnection Diagram Keowee-Oconee Interface Cabinet KOIC-A, Rev. 28
O-799-B Interconnection Diagram Keowee-Oconee Interface Cabinet KOIC-B
O-799-C - Outline and Connection Diagram Terminal Cabinet KHU-1A, Rev. 1
O-799-C-1- Outline and Connection Diagram Terminal Cabinet KHU-1B - Rev. 0
O-799-D - Outline and Connection Diagram Terminal Cabinet KHU-2A - Rev. J
O-799-D-1 - Outline and Connection Diagram Terminal Cabinet KHU-2B - Rev. 0
O-2792-D, Connection Diagram Unit Control Terminal Cabinet UCTC 7, Rev. 2
Attachment
2
OEE-163-37, Elementary Diagram SSF RC Loop Hot Leg Temp, Rev. 1
PROCEDURES
AP/0/A/2000/002, Keowee Hydro Station - Emergency-start, Rev. 15
AP/0/A/2000/003, Keowee Hydro Station - Auxiliary Power Recovery, Rev. 0
DESIGN BASIS DOCUMENTS
OSS-0254.00-00-2006, Design Basis Specification for the 125 VDC Vital Instrumentation and
Control Power System, Rev. 9
OSS-0254.00-00-2000, Design Basis Specification for the 4KV Essential Auxiliary Power
System, Rev. 20
OSS-0254.00-00-2005, Design Basis Specification for the Keowee Emergency Power, Rev. 22
OSS-0254.00-00-4013, Design Basis Specification for the Oconee Single Failure Criterion,
Rev. 4
PLANT MODIFICATIONS
NSM ON-53065, Replace Underground Power, Aux Power, & Control Cables from Keowee
Hydro-Station to Oconee Nuclear Station, Rev. 1
EC91826-OD100924, Backup Power-U1 Pressurizer Heater and Battery Chargers 1CA & 1CB
from PSW, Rev. 0
EC91830-OD100941, Unit 1 Main Control Room Board Additions for PSW, Rev. 16
EC91849-OD200925, Backup Power-U2 Pressurizer Heater and Battery Chargers 2CA & 2CB
from PSW, Rev. 7
EC91850-OD200934, Protected Service Water Test Line/Minimum Flow, Rev. 9
EC91852-OD200945, Unit 2 Outage Main Control Board Additions, Rev. 8
EC91853-OD200942, Unit 2 Pre-outage Main Control Room Board Adds for PSW, Rev. 5
EC91856-OD500921, PSW Support Equipment Installation and Testing, Rev. 37
EC91859-OD300926, Backup Power-U3 Pressurizer Heater and Battery Chargers 3CA & 3CB
from PSW, Rev. 2
EC91860-OD300935, (OMP) Protected Service Water, Rev. 15
EC91863-OD300943, Unit 3 Pre-Outage Main Control Room Board Adds for PSW, Rev. 1
EC91866-OD300955, Unit 3 Outage Main Control Room Board Adds For PSW, Rev. 4
EC91873-OD500922, PSW Power Feed Installation, Rev. 8
EC91874-OD500923, 3.8 KV Feed to PSW System from 100 KV APS, Rev. 7
EC91875-OD500927, Keowee AC Power Supply Tie-Ins, Rev. 15
EC91876-OD500928, SSF 4.16KV Alternate Power Feed from PSW, Rev. 37
EC91877-OD500932, Protected Service Water, Main Header, Rev. 18
EC91880-OD500940, Keowee Emergency-start Cable, Rev 24 (HELB Involved SY Trenches)
PLANT MODIFICATIONS
NSM ON-53065, Replace Underground Power, Aux Power, & Control Cables from Keowee
Hydro-Station to Oconee Nuclear Station, Rev. 1
EC91826-OD100924, Backup Power-U1 Pressurizer Heater and Battery Chargers 1CA & 1CB
from PSW, Rev. 0
EC91830-OD100941, Unit 1 Main Control Room Board Additions for PSW, Rev. 16
EC91849-OD200925, Backup Power-U2 Pressurizer Heater and Battery Chargers 2CA & 2CB
from PSW, Rev. 7
EC91850-OD200934, Protected Service Water Test Line/Minimum Flow, Rev. 9
EC91852-OD200945, Unit 2 Outage Main Control Board Additions, Rev. 8
EC91853-OD200942, Unit 2 Pre-outage Main Control Room Board Adds for PSW, Rev. 5
EC91856-OD500921, PSW Support Equipment Installation and Testing, Rev. 37
3
EC91859-OD300926, Backup Power-U3 Pressurizer Heater and Battery Chargers 3CA & 3CB
from PSW, Rev. 2
EC91860-OD300935, (OMP) Protected Service Water, Rev. 15
EC91863-OD300943, Unit 3 Pre-Outage Main Control Room Board Adds for PSW, Rev. 1
EC91866-OD300955, Unit 3 Outage Main Control Room Board Adds For PSW, Rev. 4
EC91873-OD500922, PSW Power Feed Installation, Rev. 8
EC91874-OD500923, 3.8 KV Feed to PSW System from 100 KV APS, Rev. 7
EC91875-OD500927, Keowee AC Power Supply Tie-Ins, Rev. 15
EC91876-OD500928, SSF 4.16KV Alternate Power Feed from PSW, Rev. 37
EC91877-OD500932, Protected Service Water, Main Header, Rev. 18
EC91880-OD500940, Keowee Emergency-start Cable, Rev 24 (HELB Involved SY Trenches)
MISCELLANEOUS DOCUMENTS
Condition Reports Written Due to this Inspection
PIP O-14-02965 (PDO) Evaluation of Dynamic Loads from Cable Faults (Cable Whip)
PIP O-14-03190 (PDO) Single failure criteria associated with Keowee underground cable
PIP O-14-5125 Cable faults on the PSW 13.8 kV Fant power path needs to be evaluated,
PDO updated 5-19-2014