ML15257A435
| ML15257A435 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/14/2015 |
| From: | Bartley J NRC/RGN-II/DRS/EB1 |
| To: | James Shea Tennessee Valley Authority |
| References | |
| IR 2015007 | |
| Download: ML15257A435 (26) | |
See also: IR 05000327/2015007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
September 14, 2015
Mr. Joseph W. Shea
Vice President, Nuclear Licensing
Tennessee Valley Authority
Chattanooga, TN 37402-2801
SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC EVALUATION OF CHANGES, TESTS,
AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS INSPECTION
REPORT 05000327/2015007 AND 05000328/2015007
Dear Mr. Shea:
On July 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
your Sequoyah Nuclear Plant, and discussed the results of this inspection with Mr. Carlin and
other members of your staff. Inspectors documented the results of this inspection in the
enclosed inspection report.
NRC inspectors documented five findings of very low safety significance (Green) in this report.
Five of these findings involved violations of NRC requirements; one of these violations was
determined to be Severity Level IV under the traditional enforcement process.
If you contest the violations or significance of the 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, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector
at the Sequoyah Nuclear Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region II; and the NRC resident inspector at the
Sequoyah Nuclear Plant.
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 Public Document Room or from the Publicly Available Records (PARS) component of
J. Shea 2
NRC's Agencywide Documents Access and Management 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/
Jonathan H. Bartley, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos.: 05000327, 05000328
Enclosure: Inspection Report 05000327/2015007
and 05000328/2015007 w/Attachment:
Supplementary Information
cc: Distribution via Listserv
__ _______________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED
OFFICE RII:DRS RII:DCI RII:DCI RII DRP
TNF1 DXT2 PJC2 AJB3
NAME TFANELLI DTERRY-WARD PCARMAN ABLAMEY
DATE 9/14/2015 9/14/2015 9/8/2015 9/14/2015 9/ /2015 9/ /2015 9/9/ /2015
/2015
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.: 50-327, 50-328
Report Nos.: 05000327/2015007, 05000328/2015007
Licensee: Tennessee Valley Authority (TVA)
Facility: Sequoyah Nuclear Plant, Units 1 and 2
Location: Soddy-Daisy, TN 37379
Dates: July 20 to 31, 2015
Inspectors: T. Fanelli, Reactor Inspector (Team Leader)
D. Terry-Ward, Construction Inspector
P. Carman, Construction Inspector
J. Bennett, (Intern)
Approved by: Jonathan H. Bartley, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
SUMMARY
Inspection Report (IR) 05000327/2015007, 05000328/2015007; 07/20-31/15; Sequoyah Nuclear
Plant Units 1 & 2; NRC Evaluations of Changes, Tests, and Experiments and Permanent Plant
Modifications.
This report covers a two-week, on-site inspection by three regional inspectors. The inspectors
identified one severity level (SL) IV non-cited violation (NCV), and four Green NCVs. The
significance of inspection findings is indicated by their color (Green, White, Yellow, Red) using
the NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated
June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within the
Cross Cutting Areas, dated December 04, 2014. All violations of NRC requirements are
dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The
Nuclear Regulatory Commissions (NRCs) program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green: The inspectors identified a Green non-cited violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, for the licensees failure to control safety related
calculations that reviewed equipment essential to the function of Class 1E electrical
systems. The issue was entered into the licensees corrective action program as CRs
1059281 and 1064042. Planned corrective actions were to revise the calculations.
The inspectors determined that the performance deficiency was determined to be more than
minor because it was associated with the Design Control attribute of the Mitigating Systems
Cornerstone. The failure to plan and control updates to safety related calculations to review
the suitability of new molded case circuit breakers in Class 1E electrical systems adversely
affected the cornerstone objective of ensuring the availability, reliability, and capability of the
systems that respond to initiating events to prevent undesirable consequences. The finding
was determined to have a cross-cutting aspect in the resolution area of Problem
Identification and Resolution [P.3], because the licensee failed to take effective corrective
actions to address issues in a timely manner commensurate with their safety significance.
(Section 1R17.b.1)
Green: The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50 Appendix
B Criterion III, Design Control, for the licensees failure to ensure that plant licensing and
design basis for shared Class 1E electrical systems were controlled and maintained. The
licensing and design basis of shared electrical systems required mechanical interlocks to
prevent an operator error that could parallel these diverse power sources in accordance with
IEEE 308-1971 and Regulatory Guides 1.81 and 1.6. A modification removed the kirk-key
interlocks. The issue was entered into the licensees corrective action program as CR
1064736. The licensee has administrative controls in place to limit the risk of this
configuration pending determination of corrective actions.
The inspectors determined that the performance deficiency was more than minor because it
was associated with the Design Control attribute of the Mitigating Systems Cornerstone and
the removal of mechanical interlocks that separated diverse shared electrical systems
3
adversely affected the cornerstone objective of ensuring the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable consequences.
The finding was determined to have a cross-cutting aspect in the conservative bias area of
Human Performance [H.14] because the licensees decision making-practices did not
emphasize prudent choices over those that are simply allowable. (Section 1R17.b.2)
SLIV: The inspectors identified a SLIV violation of 10CFR 50.59.c.(2).ii, Changes, tests and
experiments, for the licensees failure to obtain a license amendment prior to implementing
a change to the onsite emergency and shutdown AC electric systems supplying the shared
Essential Raw Cooling Water (ERCW) systems. The change removed the kirk key
interlocking system from the tie breakers that originally prevented an operator error that
would parallel the Unit 1A and Unit 2A 480V AC motor control centers (MCCs). The issue
was entered into the licensees corrective action program as CR 1076179. The licensee has
administrative controls in place to limit the risk of this configuration pending determination of
corrective actions.
The inspectors determined that the performance deficiency was more than minor because
there was a reasonable likelihood that the change required Commission review and
approval prior to implementation and the failure to request approval impacted the regulatory
process. Specifically, the departure from acceptance criteria identified in IEEE 308, RG 1.81, and RG 1.6 more than minimally increased the likelihood of occurrence of an ERCW
power train malfunction. (Section 1R17.b.3)
Green: The inspectors identified three examples of a Green non-cited (NCV) of 10 CFR 50
Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and
correct a conditions adverse to quality that were associated with processes for evaluating
Class 1E critical characteristics for molded case circuit breakers. The issue was entered
into the licensees corrective action program as CRs 1064483, 1064744, 1064479, 1059273
and 1064731. Planned corrective actions were to update procedures to document critical
thinking in evaluating CRs and include additional critical characteristics.
The inspectors determined that the performance deficiency was more than minor because it
was associated with the Equipment Performance attribute of the Mitigating Systems
Cornerstone and the failure to identify and correct nonconformances in Class 1E equipment
and the failure to resolve adverse conditions with evaluating Class 1E critical characteristics
adversely affected the cornerstone objective of ensuring the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable consequences.
The finding was determined to have a cross-cutting aspect in the change management area
of Human Performance [H.3] because Leaders failed to use a systematic process for
evaluating and implementing change so that nuclear safety remains the overriding priority.
(Section 1R17.b.4)
Green: The inspectors identified a Green non-cited violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, for the licensees failure to verify the adequacy of
defined shelf life and design life characteristics of Class 1E electrical equipment. The issue
was entered into the licensees corrective action program as CR 1064785.
The inspectors determined that the performance deficiency was more than minor because it
was associated with the Design Control attribute of the Mitigating Systems Cornerstone and
the failure to ensure the Class 1E static and dynamic performance characteristics were
identified and evaluated adversely affected the cornerstone objective of ensuring the
4
availability, reliability, and capability of the SSCs that responds to initiating events to prevent
undesirable consequences. The finding was determined to have a cross-cutting aspect in
the change management area of Human Performance [H.3] because Leaders failed to use a
systematic process for evaluating and implementing change so that nuclear safety remains
the overriding priority. (Section 1R17.b.5)
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R17 Evaluations of Changes, Tests, Experiments and Permanent Plant Modifications
(71111.17T)
a. Inspection Scope
Evaluations of Changes, Tests, and Experiments: The inspectors reviewed eight safety
evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR) 50.59,
Changes, tests, and experiments, to determine if the evaluations were adequate and
that prior NRC approval was obtained as appropriate. The inspectors also reviewed 18
screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation
was not necessary. The inspectors reviewed these documents to determine if:
- the changes, tests, or experiments performed were evaluated in accordance with 10
CFR 50.59 and that sufficient documentation existed to confirm that a license
amendment was not required;
- the safety issues requiring the changes, tests or experiments were resolved;
- the licensee conclusions for evaluations of changes, tests, or experiments were
correct and consistent with 10 CFR 50.59; and
- the design and licensing basis documentation used to support the change was
updated to reflect the change.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10
CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed
evaluations and screenings. The NEI document was endorsed by the NRC in
Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes,
Tests, and Experiments, dated November 2000.
This inspection constituted 7 evaluation samples and 13 screening and/or applicability
determination samples as defined in Inspection Procedure (IP) 71111.17-04.
Permanent Plant Modifications: The inspectors reviewed 10 permanent plant
modifications that had been installed in the plant during the last three years. The
modifications reviewed are listed below:
- DCN 23082, Option To Use Either GE Breaker Model TFJ236J110WL or
TFJ236J125WL
- DCN 23288, Replace Undersized Thermal Overload Units With Properly Sized Units
- DCN 23070, Replace Motor SQN-2-MTRB-063-0073-BEC 242408, Containment
Spray Pump Full Flow Recirculation Modification, Rev. 0
- DCN 23216-03, Modify Handswitch SQN-2-HS-062-0108C-A
- DCN 22386-03, Modify SQN-2-FCV-001-0022 -T Internals (Poppet Cover & Stem) &
Install Packing
6
- DCN 22546-11, Fire Area FAA-054, Room 714-A01, Ab Corridor: Install 3-Way
Valve For 2-LCV-3-156, -164 to Allow A Local Means of Venting off the Air to the
- DCN 23396, Issue Design Output Portion of the EOP Setpoint Calculation
SQS20110.
- DCN 22546-06, To Credit 690-A1 and 714-A1 For TDAFWP 2S-S, Cables 2SG229S,
2SG250S, 2SG251S, and 2SG252S Will Be Rerouted to Avoid 714-A1 and 690-A1.
These Will Instead Be Routed Through the Control Bldg On Elevation 706, and 685.
- DCN 22889-18, This DCN Will Replace the Custom Pull Up Module. Rack 2-R-5
- DCN 23492, Replace Obsolete RWST Level Transmitter
The modifications were selected based upon risk significance, safety significance, and
complexity. The inspectors reviewed the modifications selected to determine if:
- the supporting design and licensing basis documentation was updated;
- the changes were in accordance with the specified design requirements;
- the procedures and training plans affected by the modification had been adequately
updated;
- the test documentation as required by the applicable test programs had been
updated; and
- post-modification testing adequately verified system operability and/or functionality.
The inspectors also used applicable industry standards to evaluate acceptability of the
modifications and performed walkdowns of accessible portions of the modifications.
Documents reviewed are listed in the Attachment.
This inspection constituted 10 permanent plant modification samples as defined in IP
71111.17-04.
b. Findings
b.1 Failure to maintain control of and update safety related design output documents
(electrical calculations)
Introduction: The inspectors identified a Green non-cited violation (NCV) of 10 CFR
Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to control
safety related calculations that reviewed equipment essential to the function of Class 1E
electrical systems.
Description: The Sequoyah (SQN) Quality Assurance Program (QAP) document
Section 7 Design Control, Subsection 7.2.3 Design Analysis, stated, in part, The
performance of design analysis shall be planned and controlled. The suitability of
application of materials, parts, equipment, and processes essential to the function of a
structure, system, or component shall be reviewed to ensure that functional
requirements are met.
The inspectors reviewed Procurement Engineering Group (PEG) package 1071185AO
that evaluated replacement Cutler-Hammer MDL3800 molded case circuit breakers
(MCCBs) for equivalency to existing and obsolete Westinghouse MCCBs. These
MCCBs were used in Class 1E applications. The PEG package specified new technical
7
details for the MDL3800 such as new calibrated trip curves that were different from the
existing MCCBs. The inspectors determined that SQN-APS-003, 480VAC APS Class
1E Load coordination study, Rev. 79 was not controlled and updated to review the new
trip curves for suitability. A similar performance deficiency was identified in the last
Triennial Fire Protection Inspection (TFPI) in NCV 2014007-03. In response, the
licensee initiated Problem Evaluation Reports (PERs) 848756 and 875748. These PERs
identified that PEG packages 1071185AO and 1163452HO specified new technical
details for MCCBs that were not updated to applicable safety related calculations
including in SQN-APS-003. Because of the inspectors questions, the licensee identified
that safety related calculation, D2SDG-P213350, was not updated with the new MCCB
technical details specified in PEG package 1163452HO, which was identified in PER
848756. These PERs were referenced in the TFPI report 2014007 as associated with
the NCV. The licensee closed these PERs without completing corrective actions to
update the calculations.
The inspectors noted that in addition to PEG packages 1071185AO and 1163452HO,
Drawing 1, 2-35W716-1 Wiring Diagrams 480V MOT Cont Ctr 1A-A, 2A-A Single
Lines, Rev. 27 also referenced PEG package CQL602X-EQIV. The inspectors
requested that the licensee confirm that all safety related calculations were updated for
the PEGs packages referenced on the drawing. The licensee determined that
calculation SQN-APS-003 was not updated to include the new MCCB technical details
specified in CQL602X-EQIV. The PERs initiated because of the TFPI violation did not
identify this PEG package.
The inspectors determined that the licensee did not plan and control design analyses in
safety related calculations (design outputs) to review Class 1E equipment for suitability
as specified by the QAP. The licensee initiated condition reports (CRs) 1059281 and
1064042 to assess the findings. Planned corrective actions included updating the
calculations.
Analysis: The licensees failure to assure that the performance of design analysis was
planned and controlled and that the suitability of application of parts and equipment
essential to the function of a structure, system, or component was reviewed to ensure
that functional requirements were met, as specified in the QAP Section 7 Design
Control, was a performance deficiency. The performance deficiency was determined to
be more than minor because it was associated with the Design Control attribute of the
Mitigating Systems Cornerstone. The failure to plan and control updates to safety
related calculations to review the suitability of new molded case circuit breakers in Class
1E electrical systems adversely affected the cornerstone objective of ensuring the
availability, reliability, and capability of the systems that respond to initiating events to
prevent undesirable consequences. The finding was screened in accordance with NRC
IMC 0609, Significance Determination Process, dated April 29, 2015; Appendix A, The
Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012.
Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the
finding screened to green, because the deficiency affected the design or qualification of
a mitigating SSC but the SSC maintained its operability or functionality. The finding was
determined to have a cross-cutting aspect in the resolution area of Problem Identification
and Resolution [P.3], because the organization failed to take effective corrective actions
to address issues in a timely manner commensurate with their safety significance.
8
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in
part, that measures shall also be established for the selection and review for suitability of
application of materials, parts, equipment, and processes that are essential to the safety-
related functions of the structures, systems and components. Contrary to the above
since April 15, 2014, the licensee failed to establish measures for the selection and
review for suitability of application of materials, parts, equipment, and processes that are
essential to the safety-related functions of the structures, systems and components.
Specifically, the NRC identified examples where the licensees design control measures
failed to review for suitability technical details for components used in Class 1E systems
that were specified in PEG packages 1071185AO, CQL602X-EQIV and 1163452HO.
The finding was entered into the licensees corrective action program as CRs 1059281
and 1064042. Planned corrective actions were to revise the calculations. Because the
finding was of very low safety significance (Green) and was entered into the licensees
corrective action program this violation will be treated as an NCV consistent with section
2.3.2 of the NRC enforcement policy. This violation is identified as NCV 05000327,
328/2015007-01, Failure to maintain control of and update safety related design output
documents (electrical calculations).
b.2 Failure to Meet Design Basis Requirements to Provide Interlocks Between Shared
Onsite Emergency and Shutdown AC Electric Systems
Introduction: The inspectors identified a Green NCV of 10 CFR 50 Appendix B Criterion
III, Design Control, for the licensees failure to ensure that plant licensing and design
basis for shared Class 1E electrical systems were controlled and maintained. The
licensing and design basis of shared electrical systems required mechanical interlocks
(kirk-key) to prevent an operator error that could parallel these diverse power sources in
accordance with IEEE 308-1971 and Regulatory Guides 1.81 and 1.6. A modification
removed the kirk-key interlocks.
Description: On April 2, 2014, the licensee implemented a design modification, DCN
23085 that removed the kirk key interlocks from the crosstie breakers for the Unit 1A and
Unit 2A shared Essential Raw Cooling Water (ERCW) 480V AC motor control centers
(MCCs). The UFSAR Section 8.1.5 Design Criteria and Standards for the Electric
Power Systems, stated, in part, The design meets the intent of IEEE 308-1971 IEEE
Standard Criteria for Class IE Electric Systems for Nuclear Power Generating Stations,
Regulatory Guide (RG) 1.81 Shared Emergency and Shutdown Electric Systems for
Multi-Unit Nuclear Power Plants, and RG 1.6 Independence between Redundant
Standby (Onsite) Power Sources and between Their Distribution Systems. Standard
IEEE 308-1971 Section 4.1 General stated, in part, the Class 1E electric systems shall
be designed to assure that any Single act or event that can cause multiple equipment
malfunctions will not cause a loss of electric power to a number of engineered safety
features (ESF). Regulatory Guide 1.81 position 2, stated, in part, for multi-unit
nuclear power plants, the design of shared onsite emergency and shutdown A.C. electric
systems should conform to the recommendations contained in Regulatory Guides 1.6.
Regulatory Guide 1.6 position D.4.d, stated, in part, If means exist for manually
connecting redundant load groups together, at least one interlock should be provided to
prevent an operator error that would parallel their standby power sources. The original
design of the crosstie breakers for the Unit 1A and Unit 2A shared Essential Raw
Cooling Water (ERCW) 480V AC MCCs used kirk-key interlocks. The interlocks
prevented a single operator act from paralleling the power sources, which met the
licensing basis.
9
The UFSAR Section 1.2.2.7 Plant Electrical System, specifies that, For Unit 1, the
Plant Electric Power System consists of the main generator, the common station service
transformers, the diesel generators, the batteries, and the electric distribution system.
The UFSAR description for unit 2 is the same. The UFSAR Sections 9.2.2.2 and 9.2.2.3
[ERCW] System Description and Safety Analysis, described four independent diesels
generator power trains (two divisions per plant) starting four independent ERCW pumps
that are divided into two common ERCW header trains. The safety analysis described
the ERCW electrical design was for the loss of an entire plant emergency power train
(one of the four divisions).
The inspectors determined that each ERCW power divisions independently met the
definition of a redundant Standby Power Source each with individual Load Group as
described in RG 1.6. This design provided diversity and defense in depth for the shared
power systems. The divisions were incompatible as specified by RG1.6. An inadvertent
Interconnection between these Standby AC Power Sources could cause undesirable
interactions, as specified by RG 1.81. The original kirk key interlock design prevented
these undesirable consequences before they were removed. The licensee was required
to maintain at least one interlock to prevent an operator error that could parallel the
shared onsite emergency and shutdown AC electric systems.
Analysis: The licensees failure to ensure that at least one interlock was provided
between the Unit 1A and Unit 2A ERCW power trains to prevent a single act or event
from paralleling their power sources as specified by IEEE 308-1971, RG1.81, and
RG1.6, was a performance deficiency. The performance deficiency was more than
minor because it was associated with the Design Control attribute of the Mitigating
Systems Cornerstone and the removal of mechanical interlocks that separated diverse
shared electrical systems adversely affected the cornerstone objective of ensuring the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. The finding was screened in accordance with NRC
IMC 0609, Significance Determination Process, dated April 29, 2015; Appendix A, The
Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012.
Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the
finding was screened to green, because the deficiency affected the design or
qualification of a mitigating SSC but the SSC maintained its operability or functionality.
The finding was determined to have a cross-cutting aspect in the conservative bias area
of Human Performance [H.14] because the licensees decision making-practices did not
emphasize prudent choices over those that are simply allowable.
Enforcement: 10 CFR Part 50, Appendix B, Criterion III, Design Control, stated, in
part, that measures shall include provisions to assure that appropriate quality standards
are specified and included in design documents and that deviations from such standards
are controlled. Contrary to the above since 2014, the licensee failed to include
provisions to assure that appropriate quality standards were specified and included in
design documents and that deviations from such standards were controlled. Specifically,
design changes to the Unit 1A and Unit 2A ERCW power sources failed to include IEEE 308-1971, Regulatory Guides 1.81 and 1.6 and that deviations from them were
controlled subject to design control measures commensurate with those applied to the
original design. The issue was entered into the licensees corrective action program as
CR 1064736. The licensee has administrative controls in place to limit the risk of this
configuration pending determination of corrective actions. Because the finding was of
very low safety significance (Green) and was entered into the licensees corrective
10
action program this violation will be treated as an NCV consistent with section 2.3.2 of
the NRC enforcement policy. This violation is identified as NCV 05000327,
328/2015007-02, Failure to meet Design Basis Requirements to have Interlocks
between Shared systems.
b.3 Failure to request a licensee amendment prior to removing interlocks from shared
onsite emergency and shutdown AC electric systems.
Introduction: The inspectors identified a SLIV violation of 10CFR 50.59.c.(2).ii
Changes, tests and experiments for the licensees failure to obtain a license
amendment prior to implementing a change to the onsite emergency and shutdown AC
electric systems supplying the shared Essential Raw Cooling Water (ERCW) systems.
The change removed the kirk key interlock from the tie breakers that originally prevented
an operator error that would parallel the Unit 1A and Unit 2A 480V AC MCCs.
Description: The licensee is committed to the Nuclear Energy Institute (NEI) standard
96-07 to meet the requirements of 10 CFR 50.59. Standard NEI 96-07 Section 4.3.2,
which, stated, in part, Although this criterion [10 CFR 50.59.c.(2).ii ] allows minimal
increases, licensees must still meet applicable regulatory requirements and other
acceptance criteria to which they are committed (such as contained in regulatory guides
and IEEE standards). Further, departures from the design and performance standards
as outlined in the General Design Criteria (Appendix A to Part 50) are not compatible
with a "no more than minimal increase" standard. The UFSAR Section 8.1.5 Design
Criteria and Standards for the Electric Power Systems, stated, in part, The design
meets the intent of IEEE 308-1971, Regulatory Guide (RG) 1.6, and RG 1.81. The
original design of the ERCW system used tie breakers to interconnect the Unit 1A MCC
to the Unit 2A MCC in order to operate both from one division of AC power. Either of the
Units could provide this functional diversity and defense in depth. Kirk key interlocks on
the tie breakers prevented inadvertent interconnections between the two MCCs power
sources. As indicated by RG 1.81 and RG 1.6, inadvertent interconnections between
units could cause undesirable interactions. A modification to the MCCs removed these
kirk key interlocks and the licensee failed to identify that the design departed from the
acceptance criteria outlined in the design and performance standards mentioned above.
Further, the removal of the kirk key interlock made credible the possibility of a single act
or event paralleling the two MCCs power sources, which could now cause undesirable
interactions. The inspectors determined that this modification more than minimally
increased the likelihood of occurrence of a malfunction of the shared ERCW A train,
which would have required NRC approval prior to implementation.
Analysis: The licensees change to the facility resulted in a departure from acceptance
criteria in design and performance standards, which resulted in a more than a minimal
increase in the likelihood of occurrence of a malfunction as specified by NEI 96-07
Chapter 4, was a performance deficiency. The performance deficiency was determined
to be more than minor because there was a reasonable likelihood that the change
required Commission review and approval prior to implementation and the failure to
request approval impacted the regulatory process. Specifically, the departure from
acceptance criteria identified in IEEE 308, RG 1.81, and RG 1.6 reasonably required
commission review and approval prior to implementation. Using IMC 0609, Appendix A,
Exhibit 2, Mitigating Systems Screening Questions, the finding was screened to green,
because the deficiency affected the design or qualification of a mitigating SSC but the
SSC maintained its operability or functionality. Because this violation was evaluated as
11
having very low safety significance (i.e., green) by the SDP it was dispositioned as a
severity level (SL) IV.
Enforcement: 10CFR 50.59.c.(2).ii stated, A licensee shall obtain a license amendment
pursuant to Sec. 50.90 prior to implementing a proposed change, test, or experiment if
the change, test, or experiment would 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 previously evaluated in the final safety analysis report (as updated).
Contrary to the above since 2014, the licensee did not obtain a license amendment
pursuant to Sec 50.90 prior to implementing the change to kirk-key interlocks, which
created a more than minimal increase in the likelihood of occurrence of a malfunction of
a SSC important to safety previously evaluated in the UFSAR. The issue was entered
into the licensees corrective action program as CR 1076179. The licensee has
administrative controls in place to limit the risk of this configuration pending
determination of corrective actions. Because the finding was of very low safety
significance (SLIV) and was entered into the licensees corrective action program this
violation will be treated as an NCV consistent with section 2.3.2.a of the NRC
enforcement policy. This violation is identified as NCV 05000327, 328/2015007-03,
Failure to request a licensee amendment prior to removing interlocks from shared onsite
emergency and shutdown AC electric systems.
b.4 Failure to identify and correct conditions adverse to quality
Introduction: The inspectors identified three examples of a Green NCV of 10 CFR 50
Appendix B, Criterion XVI Corrective Action, for licensees failure to identify and correct
conditions adverse to quality that were associated with the processes for evaluating
Class 1E critical characteristics for molded case circuit breakers.
Description: Sequoyah (SQN) issued PER 406695 SQN review of Watts Bar Nuclear
(WBN) PER 403095 - Commercial Grade Dedication Process. The PER was closed
2/12/2013 with the comment that No SQN site specific cause identified. This PER will
consist of actions to review the WBN disposition of PER 403095. The inspectors
identified that the WBN PER identified weaknesses in the TVA Nuclear Power Group
(NPG) procedures for identification and verification of Class 1E critical characteristics.
The Quality Assurance Program (QAP) Section 10 Adverse Conditions, Subsection
10.1 General stated, in part, adverse conditions, including non-conforming items ,
shall be identified, evaluated, corrected, tracked, trended, and when required, reported
to appropriate levels of management. Subsection 10.2.2, Corrective Action for Adverse
Conditions states, in part, shall promptly identify and resolve adverse conditions. The
inspectors identified examples where the licensee failed to identify non-conforming items
in the corrective action program (CAP), and failed to perform adequate critical
characteristic evaluations using the corporate procedures as described in PER 403095.
Examples were identified associated with PEG package 1071185AO prepared for DCN
23085. Additional examples were identified associated with equivalent change technical
evaluation (EQV) 23082 prepared for Engineering Change Package (ECP) 23082A.
One example where a nonconformance was not entered into the CAP, resulted in a
Design Change Notification (DCN), which inappropriately accommodated nonconforming
items instead of correcting the nonconformances as specified by the QAP. The
inadequate critical characteristics evaluations did not recognize or evaluate circuit
breaker interfaces, circuit breaker weight differences, circuit breaker actuating
mechanisms, and circuit breaker temperature compensation mechanisms.
12
The inspectors reviewed TVA NPG Procedure NEP-8.4, Equivalency Evaluation for
Procurement and Use of Replacement Material and Items, Rev. 001, section 3.2.2
which stated in part In performing the Equivalency Evaluation, the Procurement
Engineer determines whether there are any differences in the physical design
characteristics of the replacement item affecting its fit, form, function, manufacturing, or
material. The inspectors interviewed the Procurement Engineering Group (PEG) staff
and determined that in some instances they relied on part numbers to procure and verify
the adequacy of electrical equipment rather than identify the critical characteristics
necessary for the component application. Further, the methods identified for
procurement engineers in the TVA NPG procedures to identify Class 1E critical
characteristics did not provide adequate technical details, which resulted in vague
interpretations by procurement engineers.
Example one: The inspectors reviewed PEG package 1071185AO, which purchased
replacement molded case circuit breakers (MCCB) under an equivalency process for
applications in the plant. The inspectors noted that the Engineering Evaluation, stated,
in part, the requirement for kirk-key interlock has been removedthe existing interlock
will be reused. Correspondences from the third party dedicator stated, in part, TVA
should identify required auxiliary devices for this breaker. In bold TVAs response
stated, that As noted above, we have determined that this breaker will not require the
addition of a kirk key interlock since the existing interlock will be reused. The existing
kirk-key interlock system was not listed as a critical design characteristic and the
interlock dimensions were not evaluated for equivalency. Sometime after receipt of the
MCCBs, while performing installation, SQN identified that the existing kirk key interlocks
were not compatible with the new MCCBs. The inspectors requested the documents,
which should have been generated per the SQN QAP and site procedures upon
discovery of the above incompatibilities. The inspectors determined that the QAP
Section 10.2.1 Control of non-conforming items, stated, in part, Organizations
responsible for items determined to be non-conforming during receipt, inspection,
construction modifications shall identify and segregate the non-conforming item
from acceptable items to prevent installation. The TVA Standard Program
Procedure (SPP) NPG-SPP-22.300, Correction Action Program, Rev. 0003, stated, in
part, An individual discovering a problem takes immediate actions to address it...
actions include reporting the problem as required and initiating or ensuring the
initiation of a problem report document. The licensee provided PERs 315158 and
356903, which were initiated during previous installation attempts. Neither PER was
initiated to resolve the non-conforming condition. The inspectors determined that no
corrective action was initiated to address the non-conforming condition when this issue
was identified. Further, this was identified as an example of deficiencies in the
evaluation of Class 1E critical characteristics as presented in PER 406695. As a result
of the issues identified by the inspectors, CR 1064483 was initiated.
Example two: A new operating handle feature was added to MCCBs and they were
noted under critical characteristic items for review. However, the equivalency evaluation
for PEG package 1071185AO stated, in part, For TVA use: no handles are used on the
breaker for opening and closing actions, therefore evaluation is not required. However,
after work related to DCN 23085 attempted to install the handle it was identified that the
rotary style breaker handle would not function with the new Cutler Hammer MDL3800
breakers. The inspectors identified that the handles were used for opening and closing
the MCCBs. This was identified as another example of deficiencies in the evaluation of
13
Class 1E critical characteristics as presented in PER 406695. As a result of the issues
identified by the inspectors, CRs 1064744 and 1064479 were initiated.
Example three: The inspectors determined from ECP 23082 titled Option to use either
GE breaker model TFJ236110WL of TFJ236125WL, Rev. A, that the EQV [the
equivalency evaluation] gives the option to use either GE breaker model number
TFJ236110WL or TFJ236125WL for breaker 2-BCTC-016-0727 which feeds ice
condenser air handling units. The inspectors reviewed SQN-APS-003 referenced by
the evaluation and determined that the ambient temperature compensation features on
the new circuit breakers were not identified or evaluated as critical characteristics. This
was identified as another example of deficiencies in the evaluation of Class 1E critical
characteristics as presented in PER 406695. As a result of the issues identified by the
inspectors, CR 1064731 was initiated.
Analysis: The licensees failure to identify and correct conditions adverse to quality for
nonconforming items and resolve adverse conditions identified in SQN PER 406695 that
were associated with evaluating Class 1E critical characteristics, as specified by the
QAP Sections 10.2.1 and 10.2.2 was a performance deficiency. The performance
deficiency was determined to be more than minor because it was associated with the
Equipment Performance attribute of the Mitigating Systems Cornerstone and the failure
to identify and segregate nonconforming items and resolve adverse conditions with
evaluating Class 1E critical characteristics as identified in SQN PER 406695 adversely
affected the cornerstone objective of ensuring the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences. The
finding was screened in accordance with NRC IMC 0609, Significance Determination
Process, dated April 29, 2015; Appendix A, The Significance Determination Process
(SDP) for Findings At-Power, dated June 19, 2012. Using IMC 0609, Appendix A,
Exhibit 2, Mitigating Systems Screening Questions, the finding was screened to green,
because the deficiency affected the design or qualification of a mitigating SSC but the
SSC maintained its operability or functionality. The finding was determined to have a
cross-cutting aspect in the change management area of Human Performance [H.3]
because Leaders failed to use a systematic process for evaluating and implementing
change so that nuclear safety remains the overriding priority.
Enforcement: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, stated,
in part, that that Measures shall be established to assure that conditions adverse to
quality, such as failures, malfunctions, deficiencies, deviations, defective material and
equipment, and nonconformances are promptly identified and corrected. Contrary to
the above since 2013, the licensee failed to assure that conditions adverse to quality,
such as failures, malfunctions, deficiencies, deviations, defective material and
equipment, and nonconformances with procurement processes were promptly identified
and corrected. Specifically, the licensee failed to identify and correct nonconformances
with Class 1E electrical equipment prior to installation, and failed to identify and correct
deficiencies in the evaluation of Class 1E critical characteristics identified in PER
406695. The issue was entered into the licensees corrective action program as CRs
1064483, 1064744, 1064479, 1059273 and 1064731. Planned corrective actions were
to update procedures to document critical thinking in evaluating CRs and include
additional critical characteristics. Because the finding was of very low safety significance
(Green) and was entered into the licensees corrective action program this violation will
be treated as an NCV consistent with section 2.3.2 of the NRC enforcement policy. This
14
violation is identified as NCV 05000327, 328/2015007-04, Failure to identify and correct
inadequate procurement evaluation processes.
b.5 Failure to Establish Static Performance Characteristics for the Qualification of
Class 1E Electrical Equipment
Introduction: The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, for the licensees failure to verify the adequacy of defined
shelf life and design life characteristics of Class 1E equipment i.e. molded case circuit
breakers.
Description: The inspectors reviewed procurement packages for DCNs 23085 and
23082 that purchased Class 1E molded case circuit breakers (MCCBs) to assess the
qualification criteria. The inspectors identified that the licensee did not establish
qualification criteria for design life. The licensee had some MCCBs installed and in
service for more than 20 years. The licensee provided a white paper that concluded,
regulatory guidance and SQN UFSAR consistently exempt 1E equipment in a mild
environment from the requirement to specify a qualified life. Maintenance and testing
programs are recognized as an acceptable method of monitoring aging effects for
equipment, which is not subjected to significant environmental stresses. SQN
[Sequoyah] 1E breaker test program, Surveillance, and periodic maintenance program
provides aging monitoring. The licensees white paper indicated that qualification is
required only for harsh environmental service conditions. The inspectors noted that
qualified life is the defined period of time for which satisfactory performance can be
demonstrated for a specific set of service conditions. Service conditions included normal
operating conditions, which included mild environments. Further, the SQN licensing
basis required the qualification of Class 1E equipment for normal operating conditions so
that it will reliably perform its safety function on a continuing basis. With age, the
probability of Class 1E equipment failure increases.
The UFSAR Section 8.1.5 Design Criteria and Standards, for electric power stated, in
part, design meets the intent of those standards and guides IEEE Std 279-1971,
IEEE Std 308-1971, and IEEE No. 323-1971. Standard IEEE 279-1971, Section 4
Requirements, Subsection 4.4 Equipment Qualification, stated, in part, the protection
system equipment shall meet, on a continuing basis, the performance requirements, for
the range of transient and steady-state conditions of both the energy supply and the
environment during normal, abnormal, and accident circumstances throughout which the
system must perform, determined to be necessary for achieving the system
requirements. Standard IEEE 308-1971 Section 4.7 Equipment Qualification required
similar qualification. Standard IEEE 323-1971 Section 1 Scope and Section 2
Purpose stated, in part, the standard describes the basic requirements for
demonstrating the qualification of Class 1 electrical equipment as required in IEEE 279
and IEEE 308. Standard IEEE 323-1971 Section 5, Method and Documentation,
specified, in part, the qualification method shall establish that each type of equipment is
qualified for its application. The documentation shall include:
- The application requirements
- The equipment specifications, and data from the qualification method used.
- The service conditions and design basis event conditions to be simulated.
15
- The type test data shall contain the static and dynamic performance
characteristics.
The inspectors determined that, the static and dynamic performance characteristics over
normal service conditions described conditions related to shelf life and design life. Per
IEEE definitions, static and dynamic performance characteristics were defined as the
operating limits given for no appreciable changes over long time intervals, such as shelf
life, and appreciable changes resulting from the application of an energy source, such as
would occur within the expected design life. Normal operating conditions were defined
as those that create operating stresses such as voltage, current loading, and
mechanical loading including anticipated overloads and periodic testing, but not
including accidents or other extraordinary events. The design life was defined as the
time during which satisfactory performance can be expected for a specific set of service
conditions. The inspectors noted that the primary consideration of design life
qualification was degradation associated with aging over long time intervals, and thus
unpredictable failures. The inspectors determined that aging from normal environmental
effects as well as induced aging from normal service conditions such as electrical and
mechanical loading affected the design life. This included the range of transient and
steady-state conditions of both the energy supply and the environment during normal,
abnormal, and accident circumstances throughout which the system must perform. This
included the determination of the shelf life for normal environmental aging. The licensee
did not establish the Class 1E static and dynamic performance characteristics under the
full range of service conditions as specified by IEEE 323-1971 and required by IEEE 279
and IEEE 308.
Analysis: The failure to define Class 1E static and dynamic performance characteristics
as specified by IEEE 323, Section 5 and as required by IEEE 279 and IEEE 308 was a
performance deficiency. The performance deficiency was determined to be more than
minor because it was associated with the Design Control attribute of the Mitigating
Systems Cornerstone and the failure to ensure the Class 1E static performance
characteristics were identified and evaluated adversely affected the cornerstone
objective of ensuring the availability, reliability, and capability of the SSCs that responds
to initiating events to prevent undesirable consequences. The finding was screened in
accordance with NRC IMC 0609, Significance Determination Process, dated April 29,
2015; Appendix A, The Significance Determination Process (SDP) for Findings At-
Power, dated June 19, 2012. Using IMC 0609, Appendix A, Exhibit 2, Mitigating
Systems Screening Questions, the finding was screened to green, because the
deficiency affected the design or qualification of a mitigating SSC but the SSC
maintained its operability or functionality. The finding was determined to have a cross-
cutting aspect in the change management area of Human Performance [H.3] because
Leaders failed to use a systematic process for evaluating and implementing change so
that nuclear safety remains the overriding priority.
Enforcement: 10 CFR Part 50, Appendix B, Criterion III, Design Control, stated, in
part, that Measures shall be established for the selection and review for suitability of
application of materials, parts, equipment, and processes that are essential to the safety-
related functions of the structures, systems and components. Contrary to the above,
since 2013, the licensee failed to establish measures for the selection and review for
suitability of application of materials, parts, equipment, and processes that are essential
to the safety-related functions of the structures, systems and components. Specifically,
the licensee failed to establish measure for the selection and review for suitability of
16
static and dynamic performance characteristics used in the design and qualification of
Class 1E electrical equipment. Because the finding was of very low safety significance
(Green) and was entered into the licensees corrective action program as CR 1064785,
this violation will be treated as an NCV consistent with section 2.3.2 of the NRC
enforcement policy. This violation is identified as NCV 05000327, 328/2015007-05,
Failure to Identify Qualification Criteria Associated with Class 1E Electrical Component
Static Performance characteristics.
4OA6 Meetings, Including Exit
On July 31, 2015, the inspectors presented inspection results to Mr. Preston Pratt and
other members of your licensees staff. On September 10, the inspectors re-exited the
inspection results with Mr. Preston Pratt and other members of your licensees staff.
The inspectors verified that any proprietary information retained by the inspectors in
order to resolve any violations or unresolved items would be disposed of properly upon
resolution of the issues.
ATTACHMENT: SUPPLEMENTARY INFORMATION
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
J. Carlin, SQN Vice President
P. Pratt, SQN Plant Manager
W. Pierce, Director of Engineering
K. Smith, Director of Training
T. Marshall, Director of Operations
E. Henderson, Licensing Manager
Z. Kitts, Licensing Engineer
R. Travis, Licensing Engineer
J. Campbell, Electrical Manager
M. Rankin, 10 CFR 50.59 Program Owner
J. Alfultis, Sr. Manager Projects
C. Roneen, Sr. Manager Design Engineering
H. Elbeitam, Engineering Support
D. Porter, SQN Operations Support
NRC personnel
W. Deschaine, Resident Inspector, Sequoyah
G. Smith, Senior Resident Inspector, Sequoyah
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
05000327, 328/2015007-01 NCV Failure to maintain control of and update safety related
design out documents (electrical calculations)
05000327, 328/2015007-02 NCV Failure to meet Design Basis Requirements to have
Interlocks between Shared systems
05000327, 328/2015007-03 NCV Failure to request a licensee amendment prior to
removing interlocks from shared onsite emergency and
shutdown AC electric systems
05000327, 328/2015007-04 NCV Failure to identify and correct inadequate procurement
evaluation processes
05000327, 328/2015007-05 NCV Failure to Identify Qualification Criteria Associated with
Class 1E Electrical Component Static Performance
Characteristics
Attachment
LIST OF DOCUMENTS REVIEWED
10 CFR 50.59 Evaluations
DCN 23216-01, Modify Handswitch SQN-1-HS-062-0108C-A
DCN 22497-03, Documentation Only
DCN 22617, Install New Unit 2 Generator Circuit Breaker, Replace USSTs 2A & 2B, Replace
Unit 2 USST Buswork
DCN 22621-01, Install One Relay and Four Fuses to Rack 2-R-73, Two Relays to Rack 2-R-75
and One Relay and Four Fuses to Rack 2-R-78, dated 01/30/2012
DCN 22621-02, Wiring Connections in 2-R-73 Between Existing Relays R090 and LR8168 and
New Relay 8297B, dated 01/30/2012
DCN 23085-03, Replace Breaker Handle, Breaker Operating Mechanism and Remove Kirk-Key
Interlock, dated 04/02/2014
DCN 22471, Implement Reactor Building Structural Modifications Required to Support Steam
Generator Replacement.
DCN 22688-04, Modifications Associated With Damper Located in DG Room 2B-B
10 CFR 50.59 Screenings
DCN 23053-02, MFPS 2B Seal Injection Controller Replacement
DCN 22564-01, Replace the Valve Disk of 1-FCV-3-136a and 1-FCV-3-136b and Implement
New Thrust Settings as a Result of the Increased Valve Factor Required to Meet Job
Requirements.
DCN 22624-4, Revise Gl 89-10 Calculation and 47A941 Drawing Series For New Maximum
Allowable Unseating Thrust of 1-FCV-68-332
DCN 22624-2, Replace Motor On Actuator of 1-FCV-63-6 and Revise GL 89-10 Calculation and
47a941 Drawing Series
DCN 22540-02, Wiring Termination Changes For Alternate Feeder Breaker 1716 of U1 6.9kv
SDBD 1A-A
DCN 23380, Revise Drift Term For Low-Low Alarm Bistable to Support Manual Time Critical
Action Evaluation
DCN 23239, Replace Level Transmitter 2-LT-63-177
DCN 22542-01, 1-PMP-70-038-B: Reroute Power Cables 1PL4742B and 1PL4743B From 480v
Shutdown Board 1B1-B to CCS Pump Motor Without Passing Through the U1 Side of the AB
Elev 714.0 and Maintaining 20 Ft Separation Between CCS Pump 1A-A and Associated
Cables
DCN 22544-16, Abandon Power Cable and Spare One Control Cable for 1-FCV-74-12. Use
Existing Spare Control Cable From 1-FCV-63-39 Unused Power Cable and One Control Cable
From 1-FCV-62-98 to Reroute Power and Control Cables to 1-FCV-74-12. Install New Cable
and Conduit to Connect to these Existing Spare/Unused Cables For 1-FCV-74-12. Spare
RMOV Bd 1A1-A Compartment 3C and Spare Remaining Unused Control Cables for 1-FCV-
68-98. Remove Local Handswitch and Respective Red/Green Indicating Lights for Valve 1-
FCV-62-98
DCN 22546, Resolve Multiple Spurious Operation Concerns With Aux Feedwater System
Related to Appendix R
DCN 23195, Install Two Channels of Spent Pool Level Instruments With Remote Readout In
MCR or Other Location
DCN 22526, Replace Boric Acid Flow Meter 2-F-62-139 With ASME Qualified Device
DCN 22528-05, Replace the SAE Gr 2 Bolting With SAE Gr 8 Bolting on 2-FCV-70-89
DCN 22564-02, Replace the Valve Disk of 1-FCV-3-179a and 1-FCV-3-179b and Implement
New Thrust Settings As A Result of the Increased Valve Factor Required to Meet Job
Requirements.
3
DCN 22625-05, Revise GL 89-10 Calculation and 47A941 Series Drawing For Valve 2-FCV-68-
333 to Include the Implementation of the Newly Established Maximum Allowable Unseating
Thrust
DCN 22437, Modify Steam Generator Manway Platforms to Improve Accessibility For
Replacement Steam Generators.
DCN 23270-01, Motor Replacement (1-MTRB-003-0047-B) For Valve 1-FCV-003-0047-B Will
Be Performed By Wo 113312383.
DCN 22542-04, 2-Pmp-70-069-A - the Local Handswitches and Cables For Ccs PMP 2A-A Will
Be Disconnected For Consistency and Eliminate All Fire Caused Spurious Failures For these
Pumps Due to these Cables.
Permanent Plant Modifications
DCN 23082, Option To Use Either GE Breaker Model TFJ236J110WL or TFJ236J125WL
DCN 23288, Replace Undersized Thermal Overload Units With Properly Sized Units
DCN 23070, Replace Motor SQN-2-MTRB-063-0073-BEC 242408, Containment Spray Pump
Full Flow Recirculation Modification, Rev. 0
DCN 23216-03, Modify Handswitch SQN-2-HS-062-0108C-A
DCN 22386-03, Modify SQN-2-FCV-001-0022 -T Internals (Poppet Cover & Stem) & Install
Packing
DCN 22546-11, Fire Area FAA-054, Room 714-A01, Ab Corridor: Install 3-Way Valve For 2-
LCV-3-156, -164 to Allow A Local Means of Venting off the Air to the LCV
DCN 23396, Issue Design Output Portion of the EOP Setpoint Calculation SQS20110.
DCN 22546-06, To Credit 690-A1 and 714-A1 For TDAFWP 2S-S, Cables 2SG229S, 2SG250S,
2SG251S, and 2SG252S Will Be Rerouted to Avoid 714-A1 and 690-A1. These Will Instead
Be Routed Through the Control Bldg On Elevation 706, and 685.
DCN 22889-18, This DCN Will Replace the Custom Pull Up Module. Rack 2-R-5
DCN 23492, Replace Obsolete RWST Level Transmitter
Licensing Bases Documents
Updated Final Safety Analysis Report
Technical Specifications and Bases
Technical Requirements Manual
Calculations
39866-CALC-C-050, Code Reconciliation for Steel Containment Vessel Modification DCN
D22471A, Rev. 1
AREVA 32-9129996, Original Steam Generator - Replacement Steam Generator Comparison
Document, Unit 2, Rev. 1
AREVA 51-9155373-000, SQN Non-LOCA Disposition of Events for CCPIT Isolation Valve
Stroke Time Change
WCAP-12455, Tennessee Valley Authority Sequoyah Nuclear Plant Units 1 and 2 Containment
Integrity Analyses for Ice Weight Optimization Engineering Report, Rev. 1
WCAP-12455 Supplement 1R, Tennessee Valley Authority Sequoyah Nuclear Plant Units 1 and
2 Containment Integrity Re-analyses Engineering Report, Rev. 1
SCG1S803, Evaluation of Shield Building Dome Access Opening, Rev. 4
SCG1S805, Steam Generator Enclosure Modification, Rev. 0
SCG1S806, Steam Generator Enclosure Modification - Design of Roof Support Frames, Rev. 2
SCG1S807, SQN Unit 2 Shield Building Dome Analysis, Rev. 0
SQN-APS-003, 480VAC APS Class 1E load coordination study, Rev. 79
2-FCV-63-073, Documentation of Design Basis review, required thrust calc, and valve &
Actuator Capability Assessment for 2-FCV-63-73, Rev. 004
4
SQN-EPS-008, Cable Ampacity Study - Voltage Level V4 & V5 in Tray, Rev. 015
SQNETAPAC, Auxiliary Power System, Rev. 053
Corrective Action Documents
CR 848756 (PER), SQN TFPI 2014007 TB-04-13 breaker substitutions have been approved
without calc update, closed 09/08/2014.
CR 406695 (PER), SQN review of WBN PER 403095 - Commercial Grade dedication Process,
closed 09/08/2014
PER 315158, the new breaker is different from the existing breaker and will need to be modified
before installation, 02/16/11
PER 365903, new breaker is different from the existing breaker, 02/13/12
PER 675922
Procedures
0-MI-IXX-000-000.R, AOV Regulator Setpoint Verification, Rev. 3
1-PI-OPS-000-003.0, Periodic Stroking of Unit 1 Time Critical Valves
AOP-C.04, Shutdown from Auxiliary Control Room, Rev. 37
NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments, Rev. 9
SQN-DC-V-3.0, Classification of Piping, Pumps, Valves, and Vessels, Rev. 19
TVA-NQA-PLN89-A Quality Assurance Program Description, Rev. 0031
NPG-SPP-22.303, CR Actions, Closure and Approvals, Rev. 0006
NEDP-2, Design Calculation Process Control, Rev. 0018
NEDP-8.2, Technical Evaluation for Procurement of Safety Related and Quality Related
Materials, Items, and Services, Rev. 0001
NEDP-8.4, Equivalency Evaluation for Procurement and Use of Replacement Materials and
Items, Rev. 001
NPG-SPP-06.9.3, Post- Modification Testing, Rev. 0006
NPG-SPP-09.3, Plant Modifications and Engineering Change Control, Rev. 0018
NPG-SPP-09.4, 10 CFR 50.59 Evaluation of Changes, Tests, and Experiments, Rev. 0009
NPG-SPP-09.9, 10 CFR 72.48 Evaluations of Changes, Tests, and Experiments for
Independent Spent Fuel Storage Installation, Rev. 0003
NPG-SPP-22.300, Corrective Action Program, Rev. 0003
Drawings
1, 2-35W716-1 Wiring Diagrams 480V MOT Cont Ctr 1A-A, 2A-A Single Lines, Rev. 27
1, 2-35W716-2 Wiring Diagrams 480V MOT Cont Ctr 1B-B, 2B-B Single Lines, Rev. 31
11448-ESK-5F Elementary Diagram, 4160V Component Cooling Pumps, Surry Power Station
Unit 1, Rev. 17, Sheet 1 of 1
11448-ESK-5F Elementary Diagram, 4160V Component Cooling Pumps, Surry Power Station
Unit 1, Rev. 17, Sheet 1 of 1
1, 2-47B630-78-1 Spent Fuel Pool, Level Instruments Configuration Settings, Rev. 1
1, 2-47B630-78-2 Spent Fuel Pool, Level Instruments Configuration Settings, Rev. 0
1, 2-47B630-78-3 Spent Fuel Pool, Level Instruments Configuration Settings, Rev. 0
1, 2-45N639-3, Wiring Diagram CO2 Fire Protection System Schematic Diagrams Sheet-3, Rev.
15
1,2-45N765-16, Wiring Diagrams 6900V Shutdown Aux Power Schematic Diagram Sheet-16
1,2-47W611-3-3, Mechanical Logic Diagram Auxiliary Feedwater System, Rev. 39
1-47W611-62-4, Mechanical Logic Diagram Chem & Volume Control Sys, Rev. 24
1,2-47W848-12, Compressed Air System Flow Diagram, Rev. 47
5
Miscellaneous Documents
1-SO-201-9, operating instructions 480V ERCW Motor Control Centers, Rev. 0025
2-SO-201-9, operating instructions 480V ERCW Motor Control Centers, Rev. 002
05000327/2014007 and 05000328/2014004 Sequoyah Nuclear Plant, Units 1 and 2 - NRC
Inspection Report
WNA-GO-00127-GEN, Spent Fuel Pool Instrumentation System Standard Product technical.
Rev. 03
WNA-IG-00506-TVA, Spent Fuel Instrumentation System Configuration, Rev. 1
WNA-TR-03149-GEN, SFPIS Standard Product, Final Design Verification Summary Report,
Rev. 03
WNA-DS-02957-GEN, Spent Fuel Pool Instrumentation System Design Specification, Ref. 3
WNA-PT-00188-GEN, Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test,
Rev. 02
SQN letter, S-415, March 23, 2011, Sequoyah Centrifugal Charging Pump Injection Tank
(CCIPT) Isolation Valve Stroke Time Increase Evaluation-N2N-072
TVA Letter to the NRC, December 22, 2010, Request to Employ Alternative Testing to IWE-
5221 Requirements in American Society of Mechanical Engineers Boiler and Pressure Vessel
Code,Section XI (2001 Edition with 2003 Addenda), Request Number 2-APP-J-1
TI-79, Low Voltage Breaker Trip Characteristics Curves, Rev. 0006
TI-79, Attachment 1, Low Voltage Breaker Trip Characteristics Curves, effective date: 02-14-
2014
TI-79, Attachment 2, Time-Current Curves, effective date: 02-14-2014
1071185AO, PEG PKG, Rev. 003
Work Orders
Work Order 115065174, implements DCN D23085 stage 4 in conjunction with WO 114227788,
work week 2016/03/14
Work Order 115065173, implements DCN D23085 stage 2 in conjunction with WO 111848065,
work week 2025/10/13
Work Order 114227788, replace existing Westinghouse MC3800 breaker with new Cutler
Hammer MDL3400 breaker, work week 2016/03/14
Work Order 112729648, perform molded case breaker testing in accordance with O-MI-317-
EBR-010.0 as well as breaker testing, dated: pre-test date 1/20/11
Work Order 111848065, perform molded case breaker testing, work week 2015/03/02
111857017, Replace Air Regulator and Pressure Relief Valve and repair air line leaks,
10/31/2012
Work Requests
Condition Reports generated as a result of the inspection
CR 1059281 Calculation SQN-APS-003 not updated.
CR 1058859 NRC identified duct cover not properly latched.
CR 1058860 NRC identified oil saturated pads in Transformer Yard.
CR 1058865 NRC identified deteriorated label under Unit 2 CGB.
CR 1058867 NRC identified unattached ground cable in Transformer Yard.
CR 1059387 Appendix R light pack deficiency.
CR 1059273 NRC identified a PEG Pkg containing a discrepancy.
CR 1059356 NRC identified Appendix R lighting deficiencies.
CR 1059406 NRC-identified temporary equipment deficiencies.
CR 1059392 Fire Protection Report lighting errors.
6
CR 1061916 Incorrect information in DCN 22437A 50.59.
CR 1062204 Calculation SQN-APS-003 revision log typo.
CR 1063734 FSAR Figures were not updated for DCN 23216.
CR 1063937 Lack of UNIDs and periodic calibration for SBO air bottles.
CR 1064042 Calculations SQN-APS-003 and D2SDJ-P213350 not updated for PEG packages.
CR 1064479 PEG pkg did not identify fit problems with breaker kirk key.
CR 1064483 Breaker not placed on hold after field fit problem identified.
CR 1064731 ECP 23082 comparative analysis did not include ambient temperature
compensation.
CR 1064736 Evaluate if removal of Kirk Key Interlock causes common mode failure between
Unit 1 and Unit 2.
CR 1064744 Initial discovery CR 315158 did not determine why the breaker did not fit properly
with the Kirk Key.
CR 1064785 Evaluate if adequate qualification criteria for electrical components per IEEE 323-
1974 are included in DCNs 23085 and 23082.
CR 1064803 DCN 22437 Containment Analysis input assumptions and 50.59 conclusions
LIST OF ACRONYMS USED
AC Alternating Current
CR Condition Report
DCN Design Chance Notice
ECP Engineering Change Package
EQV Equivalent
ESF Engineered Safety Feature
ERCW Essential Raw Cooling Water
GE General Electric
IEEE Institute of Electrical and Electronic
IMC Inspection Manual Chapter
MCC Motor Control Center
MCCB Motor Control Center Breakers
NEI Nuclear Energy Institute
NLI Nuclear Logistic
PEG Procurement Engineering Group
PER Problem Evaluation Report
QA Quality Assurance
QAP Quality Assurance Program
REG Regulatory Guide
SSC Structures, Systems, and Components
SDP Significance Determination Process
SL Severity Level
SQN Sequoyah Nuclear
TFPI Triennial Fire Protection Inspection
TVA Tennessee Valley Authority
UFSAR Updated Final Safety Analysis Report
VIO Violation