IR 05000327/1986026

Insp Repts 50-327/86-26 & 50-328/86-26 on 860319-0530. Violation Noted:Failure to Ensure Operability of Plant 480-volt Electrical Containment Penetration Overcurrent Protection Devices

ML20215F297
Person / Time
Site:	Sequoyah
Issue date:	07/07/1986
From:	Debs B, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215F291	List: IR 05000327/1986026 ML20215F288
References
50-327-86-26, 50-328-86-26, NUDOCS 8610160147
Download: ML20215F297 (17)

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UNITED STATES X

, pa aflog'o NUCLEAR REGULATORY COMMISSION REGION il

- [ "' o 101 MARIETTA STREET. g ,j

• 's ATLANTA, GEORGI A 30323

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Report Nos.: -50-327/86-26, 50-328/86-26

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-Licensee: Tennessee Valley Authority 6N 38A Lookout Place '

1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah Units 1 and 2 Inspection Conducted: Marc 19 thru May 30, 1986 inspector: _ T-94 e - _ , ~ 7/7 4 M. B. ShiriiTock, Chi'ef, Se(tion 1C Date' Si'gned Division of Reactor Projects Accompanying Personnel: A. S. Gill, NRR T.f. Alexion,NRR Approved by: N B. T. Debs, Chief, Section 1A

.Date Signed 7h Division of Rcactor Projects SUMMARY ,

Scope: These routine, announced inspections 'involveh onsite inspections in the areas of Licensee Action on Previous Inspection Findings and Surveillance Pro- ~

cedures and Record , .

-Results: Two violations were identifie . .

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8610160147 861003 PDR ADOCK 05000327 o PDR

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REPORT DETAILS Persons Contacted Licensee Employees

+C. C. Mason, Deputy Manager, Nuclear Power

+H. L. Abercrombie, Site Director

+*P. R. Wallace, Plant Manager

+ L. Gridley, Director, Nuclear Safety and Licensing

+J. E. Huston, Deputy Director, Nuclear Quality Assurance

+ R. Nickols, Attorney, Office of General Counsel

• L. M. Nobles, Operations and Engineering Superintendent

• R. W. Olson, Modifications Branch Manager

• M. R. Harding, Engineering Group Manager

+*D. C. Craven, Quality Assurance Supervisor

• • G. B. Kirk, Compliance Supervisor

• • • M. L. Frye, Compliance Engineer

• J. H. Sullivan, Regulatory Engineering Supervisor

• • • E. W. Whitaker, Licensing Engineer

• • D. L. Cosnant, Quality Surveillance Supervisor

• • • R. H. Smith, Project Engineer

• • • J. A. Dunlap, Division of Power Systems Operations Supervisor

• • • W. E. Andrews, Site Quality Manager

+M. R. Harding, Engineering Group Manager

+J. D. Hutson, Assistant Branch Chief, Division Nuclear Engineering

• W. S. Wilburn, Technical Service Manager

• H. B. Rankin, Design Services Manager

• J. Bajraszewski, Design Services

+J. K. Green, Principal Engineer, Division Nuclear Engineering

+ A. Koontzy, Principal Engineer, Division of Nuclear Engineering

+ E. Alsup, Supervisor, Nuclear Safety and Licensing

+ A. Ippolito, Nuclear Safety and Licensing

• D. Anderson, Mechanical Modifications

• D. Romine, Electrical Maintenance

• A. Scarzinski, Electrical Maintenance Supervisor

• R. L. Collins, Electrical Project Staff Engineer

• F. E. Denny, Engineering Assurance, Engineer

• A. H. Ritter, Engineering Assurance, Engineer

• L. L. McCormick,' Regulatory Engineering

• A. Purcell, Regulatory Engineering

• R. C. Murray, Mechanical Maintenance

• G. E. Duggin, Compliance

• J. Blankenship, Manager Information Services

• H. R. Rogers, Compliance Engineer B. G. Malone, Division of Power Systems Operations Other licensee employees contacted included technicians, engineers and maintenance personne .

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Nuclear Regulatory Commission-Region II

+ D. Walker, Acting Deputy Regional Administrator

+ G. Zech, Chief. Vendor Projects Branch, IE

+ R. Jenkins, Director, Enforcement & Investigation Coordination Staff

+ P. Weise, Chief, Reactor Projects Branch 1, Division of Reactor Projects (DRP)

+ W. Panciere, Deputy Division Director, Division Reactor Safety (DRS)

+ B. Shymiock, Chief, Reactor Projects Section (RPS) IC, DRP

+ E. Conlon, Chief, Plant Systems Section (PSS), DRS

+ Wilson, Acting Chief, Operational Programs Section, DRS

+ M. Jenison, Senior Resident Inspector, Sequoyah

+ E. Carroll, Jr. , Sequoyah Project Engineer, RPS 1A, DRP

+ S. Fillion, Electrical Engineer, PSS, DRS

+ Trocine, Enforcement Specialist

+ Alexion, Project Manager, Division of PWF. Licensing Project Directorate #1, NRR

+ Gill, Electrical Engineer, Electrical, Instrumentation And Controls Systems Branch, Section B, NRR

+G. K. Hunegs, Watts Bar Project Engineer, RPS 1C, DRP ,

• L. J. Watson, NRC Resident Inspector, Sequoyah

• Attended exit interview March 21, 1986

• • Attended exit interview April 10, 1986

+ Attended Enforcement Conference May 30, 1986, in Region II Office Exit Interview The inspection scope and findings were summarized on March 21 and April 10, 1986, with those persons indicated in paragraph 1 above. The following new items were identified:

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Violation 327, 328/86-26-01, Failure to adequately conduct Technical Specification (TS) 4.8.3.1 surveillance requirements to demonstrate operability - paragraph 5.a.; and failure to establish and maintain adequate surveillance instructions paragraph Unresolved Item 327,328/86-26-02, Review the resolution of the circuit breaker instantaneous trip testing interpretation between the licensee and NRR paragraph ,

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Violation 327, 328/86-26-03, Failure to implement procedure Administra-tive Instruction (AI)-12 when a condition adverse to quality was identified paragraph The licensee acknowledged the inspection findings with no dissenting com-ments. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection. At no time during the inspection period did the inspectors provide written material to the licensee. An enforcement conference was conducted in the

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Region II Office on May 30, 1986, to discuss these problems. A summary of this meeting is discussed in paragraph . Unresolved Items Unresolved items are matters which require more information in order to determine whether the~y are acceptable or may involve violations or devia-tions. One new unresolved item was identified during this inspection and is discussed in paragraph . Licensee Action on Previous Inspection Findings (92702) (Closed) Unresolved Items 327; 328/85-46-03, Determination that Sur-veillance Instruction (SI) SI-256 was adequate. During this inspection some major differences were identified between the Unit 1 and Unit 2 TS for testing of the primary and secondary containment penetration conductor overcurrent protective devices in TS, Table 3.8-1. The TS had been revised since the December inspection. Amendment # 42 for Unit 1 and Amendment # 34 for Unit 2 were issued by the NRC on January 14, 1986. These amendments revised section 3/4.8.3, "Electri-cal Equipment Protective Devices," by removing the previous table'

3.8-1. The current TS references the applicable surveillance instruc-tion number for performing the specific surveillance requiremen During the inspection performed on March 19-21, 1986, the reactor coolant pump (RCP) containment penetration overcurrent protection system was reviewed. The licensee's overcurrent protection system is composed of primary and backup protective devices. The primary pro-tective device is the RCP load breaker with a GE-IAC66K time over-current relay. The basic unit of this relay is of the induction-disk construction. The relay is set to operate with a high dropout pickup of 912 amperes, with a time dial setting of 5.5, and an instantaneous l pickup of 6080 amperes. The relay will operate in less than 0.14 seconds with the maximum calculated fault at the electrical penetration of 31,000 amperes. Maximum breaker clearing time is 0.083 seconds (5 cycles). The backup protective device is the main feeder breaker for the 6.9KV unit boards and consists of a Westinghouse type C0-8 over-current relay. The relay is set to pickup at 2000 amperes. The relay will operate in 0.76 seconds with the maximum calculated fault as indicated above. The penetration would be protected by the primary device firs If the primary device failed to clear the fault, the backup would function to clear the fault before thermal damage occurred to the penetratio During review of drawings 45N763-2, Rev. 21, " Wiring Diagrams 6.9KV Auxiliary Power Schematic Diagrams" and 45N721-1, Rev. 17, " Wiring Diagrams 6.9KV Unit Boards IA & 18 Single Lines," the inspector found that only the A and C phases had the above mentioned protection. Review of SI-256, " Periodic Calibration Overcurrent and Ground Fault Relays on 6.9-KV Reactor Coolant Pumps on 6.9-KV Unit Boards," also indicated that the B phase was not being tested as part of this S _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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This concern was discussed with the licensee during the March 21, 1986 exit meeting. During this meeting, the licensee indicated that the Office of Engineering (0E) would calculate the 8 phase to ground fault current, prior to NRC reinspection. -

During the followup inspection in April, the inspector found that the B phase on each pump. is currently protected by two ground fault protec-tive devices: a device on the RCP breaker and the backup device on the normal feeder breaker. These devices are set to trip at about 50 amperes and within 6 cycles. They have been tested, but this testing was not performed as part of SI-256. The inspector was informed that the station service transformer neutral has a 2.5 ohm grounding resistor on the common leg of the 'Y' connected secondary. The OE personnel calculated that a B phase fault to ground current would be limited to 1600 amperes maximum due to this resisto Sequoyah has only committed to the NRC to provide redundant overcurrent protection for the 0-10 second 12t thermal capability for the maximum short-circuit current versus time condition. Therefore, for the RCP pene-tration, redundant protection is required for faults above about 16,000 amperes. Since the maximum ground fault current is less than 1,600 amperes, the ground fault relays need not be included in T SI-256 was revised on April 8,1986, to incorporate changes discussed in p'aragraph . (0 pen) Violation 327; 328/35-46-04, Failure to Adequately Establish a Surveillance Instruction. This violation occurred because of improper acceptance criteria and errors in the surveillance instruction. SI-256 was revised and plant operations review committee (PORC) approved on April 8, 198 This SI revision incorporated specific tolerances, removed the distance relay test, and corrected the acceptance criteria for the target on the overcurrent relay. Removal of the distance relay test is acceptable because it is not a TS requiremen Further cor-rective action in this area will be evaluated by the inspector during future inspection (0 pen) Violation 327,328/85-46-05, Failure to Adequately Implement the Signoff and Review Provisions of Instruction SI-256 and Failure to Implement Procedure Change Requirements of AI-4. The violation occur-red because Division of Power Systems Operations (DPS0) technicians were using their Field Test Manual and Relay Setting Sheets as the controlling document for work; the licensee did nat consider the incorrect acceptance criteria to affect performance. The inadequate reviews were due to lack of familiarity with SI-256 and poor attention to detai Lack of understanding of AI-4, " Plant Instruction-Document Control," caused the improper procedure chang . .

The inspector reviewed current corrective action performed by the licensee in these areas. DPS0 personnel have been made aware of the requirements of meeting acceptance criteria in SI packages, and also how to properly change QA records. A Section Instruction Letter (SIL)

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is to be written with a checklist that will be used to revise existing instructions or in the preparation of new ones. Additional training will be conducted on proper use of acceptance criteria. Corrective action implementation will be reviewed during future inspection Within the area inspected, no new violations or deviations were identifie . Surveillance Procedures and Records (61700) The inspector reviewed SI-258, " Inspection of Molded Case and Lower Voltage Circuit Breakers Unit 1," Rev. 5 and SI-258.2, " Inspection of Molded Case and Lower Voltage Circuit Breaker Unit 2," Rev. During this review, the inspector found that SI-258 section 6.3 and SI-258.2 section 6.2 for Molded Case Circuit Breakers requires

" connecting all related circuit breaker poles in series and apply the input current through the series . connected poles." Performing the procedure as stated connects all the phase thermal overloads in serie When the input current is applied, only one thermal overload device is needed to function for the breaker to trip. Therefore, the SI accep-

, tance criteria can be met by actuating only one thermal overload'

devic However, the inspector did find that section 7.0 of these procedures, entitled " Instructions for Westinghouse Rack. Out Type Breakers," required that each phase thermal overload be tested separately fcr these breaker Functional testing of the molded case circuit breakers as procedurally specified does not assure that all circuit breaker thermal overload devices function as designed. Failure to adequately establish surveillance procedures SI-258 and SI-258.2, which were established to implement testing requirements of TS 4.9.3.1, is a violation. This violation has been combined with that identified in paragraph The inspector found that SI-258 and SI-258.2 do not test the instan-taneous trip feature of the circuit breakers. During the review of the completed SI-258 package dated September 13, 1985, the Trip Response Ranges indicated on the completed data sheets would not correlate to Table 3.8-1 of the TS (ie., Heinemann Circuit Breaker 1-BKRB-250-NJ/13, Trip Response Range .4 to 2.2 seconds on Data Sheet, TS Table Response Time 0.009 seconds). Failure to test the instantaneous trip feature of these circuit breakers does not assure that the circuit breaker func-tions as designe In Licensee Event Report (LER) SQRO-50-327/86015, Rev. 1, dated June 11, 1986, the licensee addressed nontesting of'the instantaneous trip function. The licensee stated that not testing the instantaneous

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trip was appropriate within their interpretation of the TS and was not an error. This position is based upon a verbal communication between the licensee and NRC (NRR) in 1980, which they feel established NRC concurrence with this interpretatio This issue is identified as Unresolved Item (327, 328/86-26-02) pending resolution of this inter-pretation for instantaneous trip testing between the licensee and NR The concerns over inadequate testing per SI-258 and SI-258.2 were discussed.with the licensee during the March inspection. The inspector found during the April reinspection, that Electrical Maintenance had identified numerous breakers where additional testing was needed before restart. This constituted a condition adverse to quality as defined in AI-12, Rev. 21, " Adverse Condition and Corrective Actions." However, licensee personnel failed to implement AI-12 when this condition aaverse to quality was first identified in March 198 AI-12' was esteblished to provide measures to assure that conditions adverse to qua y be promptly identified. The licensee took prompt corrective action when identified by the NRC Inspector on April 9,1986. Failure to _ implement procedure AI-12 when a condition adverse to quality was identified is a violation (327, 328/86-26-03).

In LER SQRO-50-327/86015, dated May 6,1986, and revision 1 to this LER, dated June 11, 1986, the licensee reported these conditions to the NR The inspector reviewed this LER and found that the corrective actions were adequately addressed, but not yet fully implemente The licensee's proposed TS change requested deletion of table 3.8-1,

" Containment Penetration Conductor Overcurrent Protective Device," from section 3/4.8.3.1. The deletion of this table would eliminate future TS changes and would allow more expeditious completion of required modifications. This information was provided in the licensee submittal package for the proposed change to Ms. E. Adensam from Mr. R. H. Shell, dated November 7, 198 The inspector reviewed a current document prepared by the Division of Nuclear Engineering (DNE) relating to auxiliary power and control power protection analysis data sheets and noted that penetration protective devices listed in this document could not be cross referenced to specific devices in the sis. The inspector informed the licensee that they need to have a correct list of containment penetration conductor overcurrent protective devices and to provide a basis for the devices in the list. This information was relayed to the licensee during the March inspectio During the April reinspection, the inspector reviewed a TVA memo to D. W. Wilson from G. B. Kirk, dated March 3, 1986 (RIMS # 500-860331 801). The memo requested specific information from DNE (formerly OE) for all SQN penetration protective devices that required testing in accordance with TS as applicable to both breakers and fuse .

During the enforcement conference held on May 30, 1986, the licensee indicated that they had currently identified 59 circuit breakers and approximately 700 fuses that required addition to the penetration protective device list. Subsequent Teview of the licensee's completed Unreviewed Safety Question Determination (USQD) package 86-18 (June 20, 1986) indicated that approximately 120 breakers and 318 fuse sets were actually required to be added to the lis The incomplete data resulted in inadequate surveillance instructions for meeting the TS, which caused insufficient testing to satisfy TS surveillance require-ments. These omissions affected the sample size when performing the surveillance procedure. Failure to test the proper sample of devises does not adequately verify operability of the devices per TS 4.8. The failure to maintain complete protective devices information for testing circuit breakers and fuses for containment electrical penetra-tion protection, as well as the example identified in paragraph 5.a.,

constitute.a violation of TS 4.8.3.1 (327,328/86-26-01).

In the LER (May 6, 1986), the licensee indicated that the list was developed in 1978 but-that no mechanism had been established to update the list. The submittal for the proposed TS change (dated November 7, 1984) indicated that the Sequoyah Workplan Control Form requires that all affected procedures be reviewed and revised to reflect any modifi-cations. If implemented, the SI should provide valid and updated lists of the associated plant equipment. Also, any modifications related to the overcurrent devices require an USQD to ensure the integrity and safe operation of the plant. Implementation of these administrative controls were not effective in preventing the failure to properly maintain required TS surveillance procedure Within the areas inspected, two violations were identified.

6. Enforcement Conference An Enforcement Conference was held at the NRC Region II office on May 30, 1986, to discuss TVA's apparent failure to ensure operability of Sequoyah's 480 volt electrical containment penetration overcurrent protection devices (circuit breakers and fuses). Mr. Walker made introductory remarks and stated that TVA should address NRC's concerns over safety significance, design / installation of backup overcurrent devices, TVA's actions to assure the adequacy of all electrical containment penetration overcurrent protec-tive device testing, and any generic implications for surveillances on other safety-related equipmen Licensee personnel addressed the potential safety issues by first discussing the incomplete list of fuses and circuit breakers that had been in use and the inadequate testing of the circuit breakers' thermal trips. Subsequent to NRC's identification of these problems, a review / verification by TVA's engineering design group resulted in the addition of 59 circuit breakers and approximately 700 fuses to the penetration protection list. The root cause of this problem was considered by TVA to be a lack of design contro o. . .

Although overall improvements are presently underway in the area of design control, specific actions to be taken on this item include making the penetration protection list a design document, controlled by procedure and updated under the ECN process. The fact that the list of breakers and fuses was incomplete affected the size of the sample of protective devices that were tested. Similarly, although series testing of the circuit breakers'

thermal trips was admitted by TVA to be inappropriate, the testing did verify proper operation of the common trip mechanism. The method of thermal trip testing has consequently been modified such that the circuit breaker poles are no longer connected / tested in series. TVA stated that their fuse verification (97% complete) and breaker testing (146 out of 188) had not revealed any breaker failures or misapplication of fuses that would have prevented protection of their associated penetratio Additionally, TVA indicated that the penetration protection scheme used at Sequoyah (breaker /

fuse) would still provide a reliability of 99.95% without surveillance testin NRC inspection findings also identified that the instantaneous trip function of each circuit breaker was not being tested. The licensee indicated that such testing of their molded case circuit breakers had caused breaker contact degradation due to the large amount of current required (40 to 200 times normal). TVA stated that the construction inspection instruction associated with electrical breakers required that they be originally tested for instantaneous trip currents on each individual phas Consequently, since the common trip mechanism is verified operational during thermal trip testing and the thermal trip has been verified by TVA to protect the asso-ciated penetration in all cases, the licensee does not consider such testing of molded case circuit breakers to be prudent or necessar Since 75% of Sequoyah's circuit breakers are of the molded case type, the licensee expressed a desire to only test the thermal trips on these breakers. TVA stated that such a verbal agreement was made with the NRC in 1980. The licensee indicated that both thermal and instantaneous trip tests would be performed on the remaining 25% electrically operated circuit breaker Mr. Walker informed TVA that the TS, as written, required breaker testing of j both the thermal and instantaneous trips. Any other interpretation /TS change would be considered a licensing action and require NRR approval. TVA acknowledged and indicated that such action would be pursue Regarding the generic implication for adequacy of surveillances on other safety-related equipment, both the NRC and TVA have recently identified additional deficiencies. The licensee confirmed that a special subcommittee

> had been established to evaluate all TS surveillance requirements. Prior to restart of either unit, the subcommittee is to identify each surveillance requirement and verify that plant procedures properly ensure that the intent of each requirement is met.

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Mr. Walker thanked TVA for their presentation and their information on safety significance. Mr. Walker stated that the NRC would consider this l

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9 information, but that the -lack of administrative control' to establish and maintain . complete plant design information to support surveillance require-ments was a significant failur .

Attachment:

TVA Enforcement Meeting Slides

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I N0SAFETYCONCERNS .N0N-TESTING 0FINSTANTANE0USTRIPFUNCTION NOT A TECHNICAL SPECIFICATION VIOLATION IS NOT REQUIRED TESTING ON MAJORITY OF OUR BREAKERS IS HARMFUL SUBSTANTIATE NON-TESTING SERIESTESTING0FM0LDEDCASEBREAKERS

.~ NOT APPROPRIATE VERIFIES TRIP FUNCTION CORRECTIVE ACTIONS LISTING 0FPENETRATIONPROTECTIVEDEVICES DID NOT INCLUDE ALL REQUIRED DEVICES IS NOW COMPLETE AND BEING PROPERLY IMPLEMENTED CORRECTIVE ACTIONS

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ELECTRICAL POWER SYSTEMS 3/4.8.3 ELECTRICAL EQU1PMENT PROTECTIVE DEVICES

CONTAINMENT PENETRATION CONDUC11)R OVERCURRENT PROTECTIVE DEVICES LIMITING CONDITION FOR OPERATION 3.8.3.1 All containment penetration conductor overcurrent protective devices specified in appropriate plant instructions shall be OPERABL '

SURVEILLANCE REQUIREMENTS 4.8.3.1 All containment penetration conductor overcurrent protective devices specified in appropriate plant instructions shall be demonstrated OPERABLE: At least once per 18 months: By selecting and functionally testing a representative sample of at least 10% of each type of lower voltage circuit breaker. Circuit breakers selected for functional testing shall be selected on a rotating basis. The functional test, Surveillance Instruction SNP SI-258, shall consist of injecting a current inrut at the specified set point to each selected circuit breaker and verifying that each circuit breaker functions as designed. Circuit breakers found j inoperable during functional testing shall be restored to OPERABLE

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status prior to resuming operation. For each circuit breaker found inoperable during these functional tests, an additional representa-

. tive sample of at least 10% of all the circuit breakers of the inoperable type shall also be functionally tested until no more l' f ailures are found or all circuit breakers of that type have been functionally teste POTENTIAL VIOLATION i

• The poles of the nolded case circuit breakers were connected in '

series for testin Inadequate procedure Failure to meet a surveillance requirement

, * The circuit breakers were not tested to verify the instantaneous trip functio Inadequate procedure Failure to meet a surveillance requirement UNRESOLVED ITEMS

• Are breakers that have not been tested for instantaneous trip and tested with the poles in series for the thermal trip operable?

• The listing of circuit breakers and fuses used for selecting the 10%

representative sample required to be tested each 18 months may not be

complete.

* Unresolved items taken from notes of NRC exit meeting.

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SAF E ISSUE PENEATIONPROTFLTIONSCHES(FORPEMATIONSMTREQUIRETES A. BRFER/ESE, ESE/ FUSE B. ANALYSIS BASD ON IEEE-500 (NESID 99.957, RELIABII 40 YEAR) IMSM REVIE (ELUDE SISE PIMS)

A. PIMS LICENSE PRIOR 101973 ARE NOT REQUIRD 10 TEST B. PIES LICUSD AITER 1978 (M0STLY BITY TEMAL IRIP ONLY) WITH H INF0MATION ON FUSES AND BREAES A.ALLESESBEINGEIFID(977 COMPLETE)

i B. APPROPRIATE NME OF BREARS B.1 PECEhTAGE B IFIED TO DATE C. N0 FAILURES OR HISAPPLICATIONS 10 PREV M PROTECTION PROTE(710N/EIFICATION A. CONCLUDE N0 SEri CONCEN __ - . . _ . .__ ._ -

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f M0LDEDCASEBREAKERSTESTEDWITHPOLESCONNECTEDINSERIES NOT AN APPROPRIATE ETHOD OF TESTING

" CONSIDEREDAMINIMALCONCERNBECAUSE: TESTING VERIFIED COMMON TRIP MECHANISM MOST PROBABLE FAILURE ALL TRIP DEVICES ERE STILL IN PLACE REDUNDANT PROTECTION STILL IN PLACE (VERIFIED) ACCEPTED RELIABILITY STUDY ON UNTESTED REDUNDANT PROTECTION TESTING REQUIRED 30'5 (70'5 NOT REQUIRED) TESTING HAS VERIFIED CAPABILITY TO PROTECT INITIALLYCAUSEDBYREFERENCETOANINAPPROPRIATE PROCEDURE NEMA AB-2 USED NOW HAVE UPDATED ALL INSTRUCTIONS

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IREEERS MD FUSE LISIS LIST OF FUSES MD CIDIT BEMERS 3 TECHNICAL SPEC CMPLET .

FUSE MD BEMER LISTINGS COMPLETE MD VRIFIED BY DG A. DESIS ELECTRIG L CALCULATIONS B. BREMERS MD FUSES SIMILAR 1010% TESTED C. EPRESSTATIVE SWLE ERIFIED 0. ALL FUSE E RIFIED REQUIREMEXT CME LATE:

A. BEST POSSIBLE HFORMATION B. NO 0FFKIAL PDETRATION PROTECTION ..LIST C. NO DESIG CONTROL OF PDETRATION PROTECTION LIST D. NO UPDATE TO OPERATIONS 10 REVISE LISTS CORRECT:

A. LISTS ON DESI9 CONTROL DRAWINGS B.DESIECONTROLPROCEDURE(POSITIVECONTROL)

C. UPDATE UNDER ECN PROCESS D. PLM T PROCEDURES REVISED E. DESIG PURSVING ON OTHER PLMTS (ELECTRIGL ISSVES APPROPRIATE MBER OF FUSES MD CIDIT BREEERS NOT TE C04SIDEREDHINIMALCONCERNFORTHEFOLLOWINGREASONS:

A. FUSES MD CIGIT BRERERS HSTALLED B. RELIABILIiT OF EQUIPMENT MD DESIE C. LIKE ITEMS VERIFIED (N0 GENERIC PROBLEMS)

D. POST REVIEW:

D.1 APPROPRIATE NO CIGIT BREEERS VERIFIED D.2 ALL FUSES m COMPLET .

THE ROOT GUSE OF THIS ITEM IS CONSIDERiD TO BE A LACK 0

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MEAGDENT IS TEING POSITIVE STEPS TO CORRECT THIS IS WDLE.

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IRSTMTMEDUSTRIPTEST

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' WS ASKED DURE TE IK INSPECTION E AGEED:

A.10 00WLEDGE Of PRIOR AGREDDTS B. WME Of HD CURRENTS K@ IRED (NA]0RITY)

C. I G STRY REVIEW ' C0 K E 85 FOR M 9 CURRENTS A. MAJORITY OF BREAKERS 40 TO 200 TMS CURRENT B. TESTING VERIFIED DEGRADATION ELIABILITY OF BREAKERS MD DESS A. BEAKER DESIGN ELIABLE:

A.1 SIMPLE ($UNTED IN MILD DVIRONMENT)

B. TRIP ECHMISM (FAILURE EDE):

B.1 TRIP EHMISM VERIFIED C. BREAKER / FUSE 99.95% RELIABLE E. INSTMTME0VS TEST NOT RE@IED TO VERIFY F. MNL TRIP MCTION WILL PROTEC . VEBLDISCUSSION1980 A. N K AGREED THE R L TEST WAS SUFFICIENT, UNIT 1 B. RESPONSE TIMES AS REFEREK E B.1 NK DID NOT WANT A STMDARD TECHNIDL SPEUFIGTION CHEE

C. UNIT 2 TECHNICAL SPEUFICATION NO RESPONSE TIME D. INDUSTRY REVIEW (TECHNIGL SPECIFICATION MD TESTS)

E. N K APPROVED TS WITH THE M L TEST ONLY BECAUSE OF DAMAGE / RELIABILITY /THEEL QPABILITIES/ AGREEMENT:

A. NO PRIOR NEED OR COETHENT TO TEST B. 110 FUTURE NEED OR CO E M NT TO TEST C. M CTIONS AS DESIGNED l D. REVISE LER/ TECH SPEC /FSAR l

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SMARY VE CONCIEDE HAT N0 VIOLATIE EXISTS VIH RESPEG 10 NOT TESTIE E INSTAEAE00S HIP FDETION OF TE M0LDE CASE CIRCUIT BREAR A. N0 SPECIFIC REQUIREEE 10 TEST B. PREVIOUS AGREEES BEMEN IVA AND EC (REASONABLE)

C. TESTIE CAUSES DAMAGE (ECLEAR SAFM)

D. HERNAL HST ADEQUAEY ETS HE REQUIREEE 10 VRITY E CIRCUIT BREAR MUIONS AS DESIGNE . TESTIE OF M0LDED CASE CIRCUIT BREAMS WIH TE POLES IN SERIE INAPPROPRIATE B. FERE TESTS (VEIFICATIE TESTS)

C. MINIMAL SAFETY CONCERN TE FAG THAT TE LIST OF BRMES AE FUSES ERE INCOMPLETE AFFEGS TE SIZE OF HE SAMPLE TO BE TESHD OEY. SIMILIAR ITEMS ERE BEIE VEIFIE . IDErilFIED ROOT CAUSE AE TAKING CORREGIE AGION.

! N0E OF TE ITEMS IDNIFIED IS A SAFETY CONCERN.

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