ML050540273

E-Mail, C. Smith to Charles Ogle, Et Al.., Regarding Hatch Tfpi, URI 50-366/03-06-06.

ML050540273
Person / Time
Site:	Hatch
Issue date:	12/11/2003
From:	Casey Smith NRC/RGN-II
To:	O'Donohue K, Ogle C, Payne D NRC/RGN-II
References
FOIA/PA-2004-0277, IR-03-006
Download: ML050540273 (3)

See also: IR 05000366/2003006

Text

Charles H. gle - MOw: ht-i: ri-amnfl r-ri -umi :u-,ooiu31-uo-u0 , II

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From: Caswell Smith

To: Charles Ogle; Charlie Payne; Kathleen O'Donohue' 2Z

Date: 12/11/03 7:21AM

Subject: Fwd: RE: Hatch TFPI "URI 50-366103-06-060

More info from Ken per my request.

I/\

arles . Oe RE: Hatch TFPI 'URI 50-366/03-06-06' raye I

.. . .

From: "Sullivan, Kenneth <ks~bnl.gov>

To: "'Caswell Smith'" <CFS1 @nrc.gov>

Date: 12/9103 4:14PM

Subject: RE: Hatch TFPI "URI 50-366/03-06-06"

Caswell

IN GENERAL: IF the postulated circuit failure would have a direct impact on

the operation of the credited SSD system the circuits are considered

REQUIRED CIRCUITS and must be provided with protection per III.G.2.

For a fire in FA 2104 (East Cableway) the Hatch SSAR credits the use of SSD

Path 1. Path 1 utilizes RCIC and S/RVs to provide eactor protection via

depressurization, inventory makeup, and decay heat removal. One S/RV should

be opened to begin depressurization before the reactor water level reaches

level 8 (approximately 2 1/2 hours). RCIC should be operated to aintain RPV

inventory between RPV water level 3 and 8 until the RCS is within the LPCI

operability pressure range of pproximately 135 psig (approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

into the event), at which time an additional S/RV will be opened to initiate

the alternate shutdown cooling mode of operation (ASDC).

As stated in Table 3.1-2 - The required Safe Shutdown Mode for the SRVs is

CLOSED Except for SRVs B21 -F01 3G and B21 -F01 3H which are required to be

operable in order to manually depressurize the RPV. Two S/RVs are required

to remain manually operable. - If all SRVs open then this criterion is

obvioulsy not met.

In addition, motive power for the RCIC pump Is provided by the RCIC turbine

which is driven by steam from the reactor. Therefore, In addition to other

concerns, the spurious opening of all SRVs (due to fire damage to circuits

ABE019CO8 and ABE019CO9) would impact the credited SSD (Path 1) by causing a

loss of motive steam to RCIC.

If RCIC was the only makeup system credited in the SSAR the SRV circuits

shoudl be considered as REQUIRED CIRCUITS and protected per III.G.2.

However, the SSAR does recognize the potential for this event (spurious

opening of all SRVs) and describes methods to prevent occurrence (open

liinks) or mitigate its impact on the SSD capability (use of Core Spray Loop

A). IF: the opening of links was shown to be an effective method of

preventing occurrence and/or CS Loop A was demonstrated (by documented

analysis) to be available and capable of mitigating this event I would not

have any concerns. However, I am not sure that this Is the case. At the

time of the inspection we questioned both the licensing basis and technical

adequacy/feasibility of manual actions to prevent this occurrence and we

were not provided with any objective evidence which demonstrated that CS was

capable of mitigating this event.

hope this helps -

Ken

Original Message-----

From: Caswell Smith [mailto:CFS1 @nrc.govJ

Sent: Thursday, December 04, 2003 7:58 AM

To: Sullivan, Kenneth

Subject: Hatch TFPI "URI 50-366/03-06-06"

l

harles R. Oale - RE: HatchTFPI 'GRI 50-366/03-06-06

Hi, Ken I am working on the licensee's response to our Inspection findings

and I have a question. The licensee claims that the 4-20 milli-amp

instrument circuits are not required for the SRVs to perform their design

function and are therefore associated circuits.

The logic developed by these circuits, however, are used in the 125 VDC

Class I E control circuit of of the SRVs which are required post-fire safe

shutdown equipment.

The licensee claims that this circuit is made up of two parts, one part is

the required circuit which implements the required Appendix R manual opertor

action . The other part is not rquired for Appendix R functions, and

implements the backup over-pressure protection for the nuclear boiler.

I totally disagree with this definition of an electrical circuit which is

not consistent with the definition given in IEEE 100-1977, IEEE Standard

Dictionary of Electrical and Electronic Terms.

Based on your vast experience of Appendix R regulations, can the circuit of

a required post fire safe shutdown equipment used for establishing hot

shutdown conditions be classified this way?

Appendix R, Section Ill.G.2, requires that the circuits of required post

fire safe shutdown equipment be protected from fire damage. Are the

instrument circuits required circuits and should they have been protected in

accordance with this regulatory requirement?

I would appreciate your comments, Thanks

I would appreciate your interpretation of this