ML071650508

Request for Additional Information Proposed Amendment on Bypass Test Capability of Certain Instrumentation

ML071650508
Person / Time
Site:	Cook
Issue date:	06/18/2007
From:	Tam P S NRC/NRR/ADRO/DORL/LPLIII-1
To:	Nazar M K Indiana Michigan Power Co
tam P S, NRR/ADRO/DORL, 415-1451
References
TAC MD3159, TAC MD3160
Download: ML071650508 (4)

Text

June 18, 2007Mr. Mano K. NazarSenior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106

SUBJECT:

D. C. COOK NUCLEAR PLANT (DCCNP), UNITS 1 & 2 - REQUEST FORADDITIONAL INFORMATION REGARDING PROPOSED AMENDMENT INVOLVING BYPASS TESTING CAPABILITY OF CERTAIN INSTRUMENTATION (TAC NOS. MD3159 AND MD3160)

Dear Mr. Nazar:

In a letter dated September 15, 2006, Indiana Michigan Power Company (I&M) requested anamendment to the Technical Specifications (TSs) of DCCNP, Units 1 and 2, to allow reactor trip system (RTS) and engineered safety feature actuation system (ESFAS) instrumentation to be tested in bypass. The Nuclear Regulatory Commission (NRC) staff has performed a review of the application, and has determined that insufficient information was provided. Accordingly, on February 15, 2007, the NRC staff conveyed in an e-mail to your staff a draft request for additional information (RAI) (Accession No. ML070460159), in preparation for a conference call to discuss the requested information. On March 26, 2007, the NRC staff discussed the draft RAI during a conference call with your staff. The purpose of this letter is to formally request the information described in the February 15, 2007, e-mail. The most notable omission was the lack of information on the changes to the RTS and ESFASsystems to include the bypass capability. Page 5 of the submittal, titled Technical Analysis, states that: "Hardware changes necessary to be made to the NIS [nuclear instrumentation system] and Foxboro analog/digital protection system to facilitate testing in bypass will be implemented in accordance with 10 CFR 50.59." The application did not address how the modified RTS and ESFAS meet NRC's requirements for systems at 10 CFR 50.55a(h), which endorses IEEE Standards 279, "Criteria for Protection Systems for Nuclear Power Generating Stations," and 603-1991, "Criteria for Safety Systems for Nuclear Power Generating Stations."

Accordingly, the following major design considerations need to be addressed in the submittal: 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 M. K. Nazar- 2 -Specifically, the application did not provide information showing how the RTS and ESFASsystems, as modified with bypass capability, continue to meet regulatory requirements. Also, the application does not state that you have done the failure mode and effects analysis todetermine if the failure of bypass system will not have any impact on accident analyses, or would not create new potential accidents. The current DCCNP 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 DCCNP licensing basis. If the licensing basis did not include thesetransients, neither the licensee nor the NRC could conclude that the proposed change poses no safety concern. In addition, there was no discussion on the brand and type of system, or the method used for thequalification of this system.Please provide the information as described in the February 15, 2007, e-mail, and as discussedabove and during the March 26, 2007, conference call. The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. In order to complete our timely review of your amendment application, we request your response within 30 days from the date of this letter. Please note that if you do not respond to this letter within 30 days, we may deny your application for amendment under the provisions of Title 10 of the Code of FederalRegulations, Part 2, Section 2.108. Feel free to contact me if you need clarification of this RAI.

Sincerely,/RA/Peter S. Tam, Senior Project ManagerPlant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-315 and 50-316 cc: See next page

ML071650508OFFICELPL3-1\PMLPL3-1/LAEICB/BC(A)LPL3-1/BC (A) NAMEPTam THarrisHGarg TTateDATE6/18/07 6/15/076/15/07 6/18/07 Donald C. Cook Nuclear Plant, Units 1 and 2 cc:Regional Administrator, Region IIIU.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351Attorney GeneralDepartment of Attorney General 525 West Ottawa Street Lansing, MI 48913Township SupervisorLake Township Hall P.O. Box 818 Bridgman, MI 49106U.S. Nuclear Regulatory CommissionResident Inspector's Office 7700 Red Arrow Highway Stevensville, MI 49127Kimberly Harshaw, EsquireIndiana Michigan Power Company One Cook Place Bridgman, MI 49106Mayor, City of BridgmanP.O. Box 366 Bridgman, MI 49106Special Assistant to the GovernorRoom 1 - State Capitol Lansing, MI 48909Susan D. SimpsonRegulatory Affairs Manager Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106Michigan Department of Environmental Quality Waste and Hazardous Materials Div.

Hazardous Waste & Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P. O. Box 30241 Lansing, MI 48909-7741Lawrence J. Weber, Plant ManagerIndiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106Joseph Jensen, Site Vice President Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106