ML16162A475

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Summary of 830608 Appeal Meeting W/Utils & Bechtel Re Standby Shutdown Sys Monitors for Source Range Flux & Steam Generator Pressure.Viewgraphs Encl
ML16162A475
Person / Time
Site: Oconee, Mcguire, 05000000
Issue date: 07/15/1983
From: Birkel R
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
NUDOCS 8307220636
Download: ML16162A475 (33)
v • d • e


Text

July 15, 1983 Dockets Nos. 50-269, 50-270, 50-287 and 50-370 LICENSEE:

Duke Power Company (DPC)

FACILITY:

Oconee Nuclear Station Units 16s. 1 2 and 3 McGuire Nuclear Station, Unit No. 2

SUBJECT:

SUMMARY

OF APPEAL MEETING HELD ON JUNE 8, 1983 WITH REPRESENTATIVES OF DPC TO DISCUSS SSF MONITORS FOR SOURCE RANGE FLUX AND STEAM GENERATOR PRESSURE The meeting was held to discuss an appeal by the licensee (DPC) of staff positions on requirements for the Standby Shutdown Facility (SSF) for each station. "The requtrements addressed for the Oconee Units Nos. 1, 2, and 3 pertain to process monitoring instruments for source angeflux and steam generator pressure.

The requirements addressed for the McGuire 2 unit pertain to source range flux monitors.

The attendees list and a copy of the meeting agenda utilized are enclosed.

Discussion, Using the agenda enclosed as an outline, DPC presented the case that the results of their evaluation indicated

'14t the intent of the NRC staff requirements are met for each station due to the existing SSF design and presently available instrumentation.

Although the NRC staff requirement on SSF source range monitors and steam generator pressure monitors.,remains the same s before, DPC argued the case that relief from this requirement as specifi cally applied to the Oconee and Mcuire stations was justified.

DPCs justification was made on the basis of: the NRC staff postulated scenarios involving the use of the SSF as applied to the Oconee and McGuire stations; the design philosophy incorpo rated in the SSF's functional purpose and capabilities; and, the analyzed allowable time frames relative toloss of shutdown margin during plant operation.

Based on the information exchange developed during the meeting, in conjunction with DPC's presentation and prior documentation to date, the NRC staff concluded that relief from the staff requirement to have a backup source range monitor (Oconee and McGuire) and a backup steam generator pressure monitor (Oconee only) in the SSF was warranted.

The NRC staff will prepare a Safety Evaluation Report (SER) documenting the results of the meeting.

This SER is expected to be issued on each

. 8307220636 830715 PDR ADOCK 050.00269 P

.PDR SURNAMEk..........................................

I...........................

DATE NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960

Meeting Summary

- 2 station's docket file by the NRC staff in late July 1983.

John F. Suermann, Project Manager Operating Reactors Branch #4, DL Ral ph A. Bi rkel, Project Manager Licensing Branch #4, DL Enclosures As stated cc w/enclosures:

See next page ORB#4:DL LB #I4:

oRacE SURAM

.JSuermann.;psR~

DATE NRC FORM 318 (1 M 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960

Duke Power Company cc w/enclosure(s):

Mr. William L. Porter Duke Power Company P. 0. Box 33189 422 South Church Street Office of Intergovernmental Relations Charlotte, North Carolina 28242 116 West Jones Street Raleigh, North Carolina 27603 Honorable James M. Phinney County Supervisor of Oconee County Walhalla, South Carolina 29621 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission, Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control Regional Radiation Representative 2600 Bull Street EPA Region IV Columbia, South Carolina 29201 345 Courtland Street, N.E.

Atlanta, Georgia 30308 Mr. J. C. Bryant Senior Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, South Carolina 29678 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Manager, LIS NUS Corporation 2536 Countryside Boulevard Clearwater, Florida 33515 J. Michael McGarry, III, Esq.

DeBevoise & Liberman 1200 12th Street, N.W.

Washington, D. C. 20036

McGui re Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 cc:

Mr. A. Carr Duke Power Company P.O. Box 33189 422 South Church Street Charlotte, North Carolina 28242 Mr. F. J. Twogood Power Systems Division Westinghouse Electric Corp.

P.O. Box 355 Pittsburgh, Pennsylvania. 15230 Mr. G. A. Copp Duke Power Company Nuclear Production Department P.O. Box 33189 Charlotte, North Carolina 28242 J. Michael McGarry, III, Esq.

Debevoise & Liberman.

1200 Seventeenth Street, N.W.

Washington, D. C. 20036 Mr. Wm.

Orders Senior Resident Inspector c/o U.S. Nuclear Regulatory Commission Route 4, Box 529 Hunterville, North Carolina 28078 James P. O'Reilly, Regional Administrator U.S. Nuclear Regulatory Commission, Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 R. S. Howard Operating Plants Projects Regional Manager Westinghouse Electric Corporation -

R&D 701 P.O. Box 2728 Pittsburgh, Pennsylvania 15230

MEETING

SUMMARY

DISTRIBUTION Licensee:

  • Copies also sent to those people on service (cc) list for subject plant(s).

Docket File NRC PDR L PDR ORB#4 Rdg Project Manager:

JSuermann; RBirkel JStolz aGrimes (Emerg.

Preparedness only)

EAdensam OELD NSIC ELJordan, IE JMITaylor, IE ACRS (10)

L3#4,dg NRC Meeting

Participants:

NFioravante TChan ESylvester LRubenstein OParr TNovak RIMattson HOrnstein DSheron KJabbour

MEETING OF JUNE 8, 1983 OCONEE/McGUIRE SSF NRC DPC Bechtel Corp.

JSuermann KCanady PGex (Licensing)

RBirkel JMcPherson NFioravante GSwindlehurst Texas Utilities TChan RWardell ESylvester DKluttz DWoodlan LRubenstein RRevels OParr TMcMeekin JStolz TLedford GLainas RHarris TNovak RGill RMattson HOrnstein BSheron KJabbour

Duke Power Company Oconee Nuclear Station McGuire Nuclear Station Appeal Meeting on Standby Shutdown System Instrumentation June 8, 1983

AGENDA STANDBY SHUTDOWN SYSTEM (SSS) INSTRUMENTATION OCONEE NUCLEAR STATION / McGUIRE NUCLEAR STATION DUKE POWER / NRC JUNE 8, 1983 I,

INTRODUCTION (K. S. CANADY)

II. SSS DESIGN -

OVERVIEW (T. C. McMEEKIN)

III, RESPONSE TO NRC STAFF REQUIREM ENTS (J. A. MC1PHERSON)

(D. E. KLUTTZ)

A. SOURCE-RANGE NEUTRON FLUX B. STEAM GENERATOR PRESSURE IV. CLOSING REMARKS (K. S. CANADY)

V, DISCUSSION

PURPOSE RESOLVE NRC CONCERNS ABOUT STANDBY SHUTDOWN SYSTEM (SSS)

MONITORING INSTRUMENTATION AT MCGUIRE AND OCONEE RELATIVE TO ALTERNATE SHUTDOWN CAPABILITY REQUIRED BY 10 CFR 50, APPENDIX R,

BACKGROUND

  • SER's REQUIRED THE FOLLOWING ADDITIONAL INSTRUMENTATION:

SOURCE-RANGE NEUTRON FLUX STEAM GENERATOR PRESSURE (OCONEE ONLY)

  • MCGUIRE UNIT 2 LICENSE CONDITION REQUIRED SCHEDULE COMMITMENT
  • DUKE REQUESTED A MEETING TO RECONSIDER REQUIREMENTS
  • DUKE MET THE LICENSE CONDITION BY PROVIDING A PROVISIONAL SCHEDULE FOR INSTALLATION PENDING APPEAL

OCONEE NUCLEAR STATION STANDBY SHUTDOWN FACILITY SIGNIFICANT EVENT CHRONOLOGY JAN 18 1978 Duke Presentation to NRC Staff JAN 25 1978

  • Submittal Concerning Post-fire Shutdown Capability FES 1 1978 s Formal Submittal of SSF Proposal APR 14 1978 9

Fire Protection/Suppression Appeal MAY 18 1978 i NRC Request for Additional Information JUN 2 1978 is NRC Staff Presentation to ACRS JUN 19 1978 e

Duke Submittal of Additional Information DEC 29 1978

  • NRC Staff Approval of Conceptual Design MAR 28 1980 t Final Design Proposal Submitted by Duke OCT 27 1980 e NRC Request Concerning Conformance with Standard Review Plan FEB 16 1981 a

Duke Submittal of Additional Information FEB 19 1981 Appendix R to 10CFR50 Secomes Effective MAR 18 1981 Duke Submittal of Additional Information MAR 31 1981 Duke Submittal of Additional Information APR 30 1981 Duke Submittal of Additional Information SEP 8 1981 s

Duke Presentation to ACRS JAN 25 1982-Duke Submittal of Additional Information APR 13 1982

  • Duke Submittal of Additional Information SEP 20 1982
  • Duke Submittal of Additional Information DEC 23 1982 e

Duke Submittal of Additional Information APR 1983 5SF Safety Evaluation Report

MCGUIRE NUCLEAR STATION STANDBY SHUTDOWN FACILITY SIGNIFICANT EVENT CHRONOLOGY MAR 23 1978 Duke Presentation to NRC Staff APR 14 1978 a

Fire Protection/Suppression Appeal MAY 1 1978 Formal Submittal of SSF Proposal JUN 2 1978 a

NRC Staff Presentation to ACRS JAN 31 1979

  • Duke Provides Revised Fire Protection Review MAR 1979 &

Supplement 2 to SER Approves SSF Concept MAR 31 1980 e Final Design Proposal Submitted by Duke FEB 19 1981 a

Appendix R to 10CFR50 Becomes Effective SEP 8 1981 Duke Presentation to ACRS OCT 21 1981 Duke Submittal of Additional Information OCT 12 1981 a

Duke Submittal of Additional Information DEC 14 1982

  • Duke Submittal of Additional Information JAN 5 1983 a

Duke Submittal of Additional Information FEB 22 1983

  • Duke Submittal of Additional Information FEB 1983 a Supplement 6 of McGuire SER Issued

SSF DFSIGN BASIS TO PROVIDE AN ALTERNATE flEANS TO ACHIEVE AND MAINTAIN A HOT SHUTDOWN CONDITION IN ALL UNITS AT EACH SITE IN THE EVENT THAT OTHER S/D SYSTES BECCfE UNAVAILABLE DUE TO FIRE., SABOTAGE OR T. B, FLOODING (OCONEE ONLY),

SSF DESIGN FUNCTItS

1) MIAINTAIN ADEQUATE PRIARY SIDE COOLANT VOLUE
2) 'lAINTAIN ADEQUATE SECONDARY SIDE COOLNT VOLUME
3) UTILIZE PRIMARY SIDE NATIPAL CIRCULATION
4) UTILIZE AETDISPHERE AS HEAT SINK VIA SECONDARY SIDE STEAMi RELIEF
5) PROVIDE SUPPORTING SERVICES, INSTRUMENTATION, PCWER SUPPLY, ETC

STANDBY SHUTDOWN SYSTEMS TIME LIMITATIONS WITHOUT DAMAGE CONTROL MEASURES Oconee McGuire Secondary Side Water

  • 3.5 days

- 3.5 days Primary Side Water 3 days

- 3.5 days Power Supply 7 days 7 days

Uk4IT I

Ui4iT 2.

STEAM DRIVEN AUX FW PUMP (AUX BLDG)

MOTOR DRIVEN AUX F4 PUMP (AuY BLDG)

STANDBY MAKEUP PUMP (REACT BLDG)

CHARGING PUMP (AUX BLDG)

DIESEL GENERATOR (SSF)

DIESEL GENERATORS (AUX BLDG)

LOAD CENTER (SSF)

CONTROL COMPLEX (AUX BLDG)

MOTOR CONTROL CENTER (SSF)

SUPPORT EQUIPMENT (

LDG)

INVERTER (SSF)

BATTERY & CHARGER (SSF)

TRANSFORMER/REGULATOR (5SF)

SHUTDOWN PANELS (SSF)

HVAC (SSF)

Diesel Generator Keowe Switchgear Emrgency Feedwater Pump Load Center Motor Control igh Pressure Injection Pump MotorContolCnterLow Pressure Service Water Pump Battery F. Chargers Control Complex Inverters Support Equipment Transformers/Regulators High Head Aux Service Water Pump Emergency Makeup Pump Shutdown Panels N VAC

MCGUIRE REACTIVITY CONTROL SOURCE RANGE NEUTRON FLUX MONITORING

  • Purpose
  • NRC Position
  • Duke Position
  • Evaluation of Postulated Fire Induced Boron Dilution Events
  • Conclusion

PURPOSE To address NRC Staff concerns regarding potential boron dilution events due to fire induced spurious.

operation of components,

NRC STAFF POSITION MCGU IRE For an in-containment fire, spurious valve operation may result in the need for continuous charging system operation.

Coupled with operator error in aligning the charging system water source, and failure to quickly detect that error, boron dilution events could be expected. Therefore, source range neutron flux instrumentatiQn should be provided in the Standby Shutdown Facility (SSF) control room.

DUKE POSITION MCGUIRE After complete evaluation, we have concluded that fire induced spurious operation and/or operator error resulting in unisolable RCS leakage coincident with unborated makeup is unlikely. Even if boron dilution did occur existing instrumentation is adequate to detect this event, Corrective actions would be taken before shutdown margin loss.

There fore, source-range neutron flux instrumentation in the Standby Shutdown Facility (SSF) is unnecessary.

FIRE INSIDE CONTAINMENT

  • Plant control is not transferred to the Standby Shutdown Facility (SSF) for an in-containment fire. The Plant is controlled from the Control Room.
  • ,McGuire 1 source-range neutron flux instrumentation-cables are separated by Appendix R distances inside containment.

Instrument readout is in the Control Room,

  • McGuire 2 source-range neutron flux instrumentation cables are separated by Appendix R distances inside containment except for one section approyimately sixty feet long, Instrument readout is in the Control Room,

BORON DILUTION EVENTS Boron dilution events are unlikely since a spuriously initiated unisolable flowpath would have to occur coincident with operator error in aligning the makeup flowpath, The operator will have reliable valve position indication in the Control Room for any in-containment fire.

If a boron dilution event did occur, it would be detected by:

1) Operator verification of RCS makeup alignment to borated source.
2) Rapid pressurizer level increase if no.RCS leakage path existed.
3) Boron sampling and analysis if an RCS leakage path existed.

Worst case boron dilution event analysis (at hot standby) indicates that unborated makeup at the maximum flow rate must continue for 106 minutes before re-criticality.

CONCLUSION As indicated in this presentation

  • Plant shutdown is controlled from the Control Room for any in-containment fire
  • Source-range neutron flux indication will be available in the Control Room for any in-containment fire for McGuire Unit I
  • Source-range neutron flux irLdication.will.be available in the Control Room for most in-containment fires for McGuire Unit 2
  • Boron dilution events are unlikely

. Boron dilution events that do occur are readily detectable

. The worst case boron dilution event requires 106 minutes of unmitigated maximum flow of unborated water to cause criticality Therefore, Duke Power ComQany believes that source-range neutron flux indication in the Standby Shutdown Facility is not necessary.

OCONF:

NRC REQUEST FOR NEUTRDN SOURCE RANGE FLUX INSTRUMENTATION A. INTRODUCTION

1.

NRC POSITION

2.

DUKE POSITION B. SCENARIO

1.

INSIDE REACTOR BUILDING FIRE (A) CONTROL ROOM CONTROL (B) DILUTION NOT CREDIBLE (C)

INTERLOCKS TERMINATE DEBORATION (D)

SOURCE RANGE INSTRUMENTATION AVAILABLE

2.

OUTSIDE REACTOR BUILDING'FIRE (A)

CONTROL FROM EITHER SSF OR CONTROL ROOM (B)

BORON DILUTION DUE TO "SPURIOUS VALVE OPERATION" CREDIBLE BUT UNLIKELY (C) ANALYSIS SHOWS 2 HOURS 35 MINUTES TO REACH CRITICALITY (D) BORON DILUTION CAUSES PRESSURIZER LEVEL INCREASE (E) OPERATOR MONITORS PRESSURIZER LEVEL PER PROCEDURE (F)

OPERATOR WILL VERIFY HPI STATUS/SOURCE PER PROCEDURE (G) BORON DILUTION IS TERMINATED C. CONCLUSION

1.

BORON DILUTION UNLIKELY

2.

BORON DILUTION READILY RECOGNIZED AND TERMINATED 3,

SOURCE RANGE INSTRLMENTATION IN SSF IS NOT NECESSARY

OCONE:

NRC POSITION ON SOURCE RANGE FLUX 1NSTELFFTATION IN THE SSF THE NRC POSITION ON SOURCE RANGE FLUX IN THE OCONEE SER SECTION 4.7.4.1 IS AS FOLLOWS:

"MONITORING OF CORE FLUX PROVIDES THE ONLY DIRECT INDICATION OF THE REACTOR SHUTDOWN CONDITION,

.THE MONITORING OF OTHER PROCESS VARIABLES WOULD PROVIDE AN INFERRED ANSWER ONLY.

WITH REGARD TO THE FISSION PROCESS, CHANGES IN NEUTRON FLUX PROVIDE THE QUICKEST AND ONLY DIRECT MEANS OF ASSESSING REACTOR CRITICALITY.

DILUTION EVENTS CAUSED BY THE POSTULATED SPURIOUS OPERATION OF VALVES COULD RESULT IN POWER EXCURSIONS 'WHICH WOULD NOT'BE READILY DETECTED BY INTERPRETING THE CHANGES IN OTHER PROCESS VARIABLES.-.

OCON:

DUKE POSITION ON SOURCE RANGE FLUX ISTEDUIVATION IN THE SSF AFTER COMPLETE EVALUATION, DUKE HAS CONCLUDED THAT FIRE-INDUCED SPURIOUS VALVE OPERATION RESULTING IN UNBORATED MAKE-UP IS UNLIKELY.

EvEN IF SUCH A BORON DILUTION EVENT DID OCCUR, IT VOULD BE DETECTED WITH OTHER EXISTING INSTRUMENTATION, CORRECTIVE ACTIONS WOULD BE TAKEN BEFORE SHUTDOWN MARGIN LOSS; THEREFORE, SOURCE-RANGE NEUTRON FLUX INSTRUMENTATION IN THE OCONEE STANDBY SHUTDOWN FACILITY (SSF)

IS UNNECESSARY,

AB--RB FC R.C. BLEED HP-120 I

HOLDUP TANK RCMA 11,000 CU.FT.

R C MAKE-UP HP-26 DEBORATING DEMINERALIZER CS-56 FC R.C. BLEED AB-- RB HP-15 TRANSFER PUMP PURIFICATION L-.

DEMINERALIZER P FC L_

INTERLOCKED TO CLOSE; (I) WHEN INTEGRATED PRESET FLOW HP-18 IS REACHED OR HPI PUMP "A" HPI PUMP"B" LETDOWN (2)GROUP 6 RODS HAVE STORAGE BEEN INSERTED TO TANK 750% FULL STROKE HP-24 WE E

HP-25 OCONEE I, 2 OR 3 REACTOR COOLANT DILUTION PATH BORATED WTR.

STORAGE TANK

OCONF:

NRC REQUEST FOR STEAM ENERATOR PRESSURE INSTRUENTATION IN THE SSF A. INTRODUCTION

1.

NRC POSITION 2.. DUKE POSITION B. SSF DESIGN/CONTROL PHILOSOPHY

1.

SSF SHUTDOWN CONTROL PROCEDURES/TRAINING SPECIAL & SEPARATE FROM NORMAL PLANT

2.

PROVIDE CONTROLLED HEAT SINK AND INVENTORY FOR RCS "HOT SHUTDOWN" COOLING FROM SSF:

-MONITOR/MAINTAIN RCS PRESSURIZER LEVEL MONITOR/MAINTAIN RCS THOT & TCOLD

-PRESSURIZER HEATER CONTROL WITH REGULATED STEAM GENERATOR PRESSURE, RCS HEAT REMOVAL RATE CAN BE DIRECTLY MONITORED BY RCS PARAMETERS AND CONTROLLED BY STEAM GENERATOR LEVEL WITHOUT STEAM GENERATOR PRESSURE

C. RCS OVERCOOLING

1.

DIRECT DETECTION OF OVERCOOLING BY

  • TCOLD DECREASING
  • RCS PRESSURE DECREASING
  • RCS PRESSURIZER LEVEL DECREASING

'STEAM GENERATOR LEVEL CHANGING

2.

CORRECTIVE ACTION

'MAKE UP TO RCS, USE PRESSURIZER HEATERS AS NECESSARY

3.

WITH REGULATED (OR LOSS OF) STEAM GENERATOR PRESSURE DURING OVERCO0LINGj RCS HEAT REMOVAL RATE CHANGES ARE DIRECTLY MONITORED BY RCS PARAMETERS AND STEAM GENERATOR LEVEL AND STABILIZE WITHOUT STEAM GENERATOR PRESSURE D CONCLUSIONS

1.

WITH REGULATED'STEAM GENERATOR PRESSURE THE ONLY PARAMETERS NEEDED FOR "HOT SHUTDOWN ARE

-PRESSURIZER LEVEL RCS PRESSURE, TC0LDj THOT

  • STEAM GENERATOR LEVEL
2.

STEAM GENERATOR PRESSURE IS NOT NECESSARY FOR MAINTAINING HOT SHUTDOWN

3.

TRANSLATION FROM "HOT SHUTDOWN" TO "COLD SHUTDOWN" MODE REQUIRES ADDITIONAL INSTRUMENTATION AND EQUIPMENT WHICH WILL BE AVAILABLE THROUGH DAMAGE CONTROL MEASURES.

THUS, STEAM GENERATOR PRESSURE INSTRUMENTATION IS NOT REQUIRED IN THE SSF,

OCONEE:

NRC POSITION ON SSF STEM GENEPATOR PRESSURE INS1R~lhlATION HE NRC POSITION ON STEM GENRATOR PRESSURE IN THE OCONEE SER SECTION 4,7.4.2 IS AS FOLLOWS:

"MAINTENANCE OF LEVEL IN THE STEAM GENERATORS MAY NOT BE SUFFICIENT IN ITSELF TO CONTROL THE HEAT REMOVAL RATE AND THEREBY MAINTAIN A "HOT STANDBY" OR "HOT SHUTDOWN'

MODE, OR TRANSLATE FROM A "HOT SHUTIOWN" MODE TO A "COLD SHUTDOWN' MODE. t

OCONFF:

DUKF POSITION ON SSF STEAKGENERATOR PRESSURE INSTRU fEATION SSF STEAM GENERATOR PRESSURE IS NOT NECESSARY BECAUSE SSF SECONDARY SIDE CONTROL/DESIGN PHILOSOPHY IS BASED ON STEAM GENERATOR LEVEL STEAM GENERATOR LEVEL PROVIDES POSITIVE INDICATION OF AVAILABLE HEAT SINK FOR RCS STEAM GENERATOR LEVEL PROVIDES D.IRECT INDICATION OF CHANGING CONDITIONS OF HEAT SINK (1,E.,

OVERCOCLING, UNDERCOOLING)

  • RCS PARAMETERS PROVIDE DIRECT INDICATION OF RCS COOLING RATE:
  • TCOLD

'THOT

-PRESSURIZER LEVEL

CONCLUSION THE DUKE STANDBY SHUTDOWN SYSTEM DESIGN IS UNIQUE, THE STAFF.REQUIREMENTS FOR ADDITIONAL SSS INSTRUMENTATION HAVE BEEN REVIEWED ON BOTH OCONEE AND McGUIRE.

THE RESULTS.OF THE EVALUATION INDICATE THAT THE EXISTING SSS DESfGN AND INSTRUMENTATION ARE ADEQUATE TO ADDRESS STAFF CONCERNS, SOURCE RANGE FLUX INSTRUMENTATION IN THE SSS IS NOT REQUIRED FOR McGUIRE OR OCONEE.

STEAM GENERATOR PRESSURE INSTRUMENTATION IN THE SSS IS NOT REQUIRED FOR OCONEE,

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