ML18330A126
| ML18330A126 | |
| Person / Time | |
|---|---|
| Issue date: | 10/26/2018 |
| From: | NRC/NRR/DIRS/IRIB |
| To: | |
| Govan T | |
| References | |
| NEI 96-07 | |
| Download: ML18330A126 (48) | |
Text
removedmoved
qualitative assessment
failuresfunction
failures function
adversenot adverse
response time response time
response time
response time response time response time "The HFE evaluation determined that the modification impacts the operator's ability to respond by requiring four actions instead of one action. And the additional actions result in an increase in the operator's time to respond. However, the actions continues to take place and the HFE professional determined that the operator actions were timely and comparable."
technical
Generally, only malfunctions are identified in the UFSAR, not
the initiators of the malfunctions
safety analyses
compensatory actions
In the proposed design, all four SBCS turbine bypass valves could also fail open concurrent with the failure of the pressurizer control system due to a software CCF in the digital control system.
A 10 CFR 50.59 Evaluation is required for digital modifica tions that adversely affect design functions, or the methods used to perform or control design functions. There is no regulatory requirement for a proposed activity involving a digital modification to default (i.e., be mandatorily "forced") to an adverse conclusion.
Notes from meeting: NEI believes this sentence was generic and redundant and therefore not needed. NRC agrees that the paragraph is clear without the deleted sentence.
Notes from meeting: Resolved per comment A25.
If all design basis functions continue to be performed/satisfied, and there are no other design functions involved, then the proposed activity does NOT create the possibility for a malfunction of an SSC important to safety with a different result because no malfunction occurs. With no malfunction occurring, there cannot be a different result.
Notes from meeting: No action. NEI added this language for completeness. NRC will document accordingly in response letter.
Notes from meeting:
NEI will take no action on this comment. NRC believes this is an error in the document.