ML070460159
| ML070460159 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/15/2007 |
| From: | Tam P NRC/NRR/ADRO/DORL/LPLIII-1 |
| To: | Scarpello M, Simpson S, Steinmetz K Indiana Michigan Power Co |
| References | |
| TAC MD3159, TAC MD3160 | |
| Download: ML070460159 (2) | |
Text
From:
Peter Tam To:
Keith Steinmetz; Michael Scarpello; Sue Simpson Date:
02/15/2007 7:23:54 AM
Subject:
D.C. Cook - Draft RAI re. RTS and ESFAS Instrumentation Amendment (TAC MD3159 & MD3160)
Keith:
By application dated 9/15/06, you requested an amendment to revise the D. C. Cook TSs to allow reactor trip system (RTS) and engineered safety feature actuation system (ESFAS) instrumentation to be tested in bypass. The staff has performed a review of the application, and has determined that insufficient information was provided as described below.
The most notable omission was the lack of information on the changes to the RTS and ESFAS systems to include the bypass capability. Page 5 of the submittal, titled Technical Analysis, states that: "Hardware changes necessary to be made to the NIS and Foxboro analog/digital protection system to facilitate testing in bypass will be implemented in accordance with 10 CFR 50.59." Standard Review Plan, Chapter 7, states that the review should include an evaluation of the protection system design against the requirements of ANSI/IEEE Std 279, or Reg. Guide 1.153, which endorses IEEE Std. 603, depending upon the applicant/licensees commitment regarding design criteria. The RTS review should address all topics identified as applicable by Table 7-1. Major design considerations that should be emphasized in the review of the RTS are:
Design basis Single failure criterion Quality of components and modules Independence Defense-in-depth and diversity System testing and inoperable surveillance Use of digital systems Same requirements are also applicable to ESFAS instrumentation. The application does not provide information showing how the bypass system capability meets all of the above guidance.
Also, the application does not state that you have done the failure mode and effects analysis to determine if the failure of bypass system will not have any impact on accident analyses, or would not create new potential accidents. The current DC Cook licensing basis does not include any mass addition transients or accidents. As such, a change in the ESFAS or RTS system that creates the possibility for an inadvertent injection of water into the reactor coolant system (such as the inadvertent start of a charging pump), would require the licensing basis to include mass addition transients in the DC Cook licensing basis. If the licensing basis did not include these transients, neither the licensee nor the NRC could conclude that the proposed change poses no safety concern. There was no discussion on the brand and type of system, or the method used for the qualification of this system.
Please call me to set up a conference call to discuss the above with our reviewer Hukam Garg.
This e-mail aims solely to prepare you and others for the proposed conference call. It does not formally request for additional information, and it does not convey a formal NRC staff position.
CC:
Hukam Garg; John Nakoski; William Bennett Mail Envelope Properties (45D450DA.478 : 12 : 35330)
Subject:
D.C. Cook - Draft RAI re. RTS and ESFAS Instrumentation Amendment (TAC MD3159 & MD3160)
Creation Date 02/15/2007 7:23:54 AM From:
Peter Tam Created By:
PST@nrc.gov Recipients Action Date & Time aep.com Transferred 02/15/2007 7:24:37 AM kasteinmetz (Keith Steinmetz) mkscarpello (Michael Scarpello) sdsimpson (Sue Simpson) nrc.gov OWGWPO01.HQGWDO01 Delivered 02/15/2007 7:24:04 AM WTB1 CC (William Bennett)
Opened 02/15/2007 7:24:34 AM nrc.gov OWGWPO02.HQGWDO01 Delivered 02/15/2007 7:24:04 AM HCG CC (Hukam Garg)
Opened 02/15/2007 8:37:12 AM nrc.gov TWGWPO01.HQGWDO01 Delivered 02/15/2007 7:24:05 AM JAN1 CC (John Nakoski)
Opened 02/15/2007 7:33:20 AM Post Office Delivered Route aep.com OWGWPO01.HQGWDO01 02/15/2007 7:24:04 AM nrc.gov OWGWPO02.HQGWDO01 02/15/2007 7:24:04 AM nrc.gov TWGWPO01.HQGWDO01 02/15/2007 7:24:05 AM nrc.gov Files Size Date & Time MESSAGE 5276 02/15/2007 7:23:54 AM Options Auto Delete:
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