ML20045C115
| ML20045C115 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/07/1993 |
| From: | Jabbour K Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9306220093 | |
| Download: ML20045C115 (24) | |
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UNITED STATES t
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WASHINGTON, D.C. 20555-0001 June 7, 1993 Docket Nos. 50-321 and 50-366 LICENSEE: Georgia Power Company, et al.
FACILITY: Hatch Nuclear Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF MAY 12, 1993, MEETING ON THE DIFFERENCES BETWEEN THE EMERGENCY OPERATING PROCEDURES AND THE LICENSING BASIS Introduction On May 12, 1993, the NRC staff met with Georgia Power Company representatives (GPC or licensee) in Rockville, Maryland, to discuss the licensee's process for assessing the differences, at Hatch Nuclear Plant, between the emergency operating procedures (EOPs) and the licensing basis. lists the attendees, and Enclosure 2 contains the meeting agenda.
Discussion The meeting was held at NRC staff request as a followup to a letter from W.
Russell, NRC, to R. Binz IV, Chairman, BWR Owners' Group (BWROG), dated May 12, 1992. After brief introductory remarks by NRC and GPC regarding the objective of the meeting, Mr. O. Vidal, GPC, stated that the licensee had reviewed each event in the transient and accident analyses (i.e., Chapters 14 and 15 of the Final Safety Analysis Report (FSAR)) and compared it to the appropriate E0P.
For example, the sequence of events listed in the FSAR for the loss of feedwater flow event was compared to the reactor water level control path of Hatch E0Ps. The comparison focused on whether or not the event listed in the FSAR resulted in an E0P entry condition.
If the event resulted in an E0P entry condition, then the licensee investigated the differences between the E0P and the FSAR actions.
For the differences identified, the licensee analyzed them as potential unreviewed safety questions and developed resolutions for all of them, using the guidance generated by the BWROG task force regarding this issue.
The licensee's resolutions were reviewed and independently verified by General Electric.
The licensee reviewed 39 events for Hatch Unit I and 42 events for Hatch Unit 2.
Moreover, all other sections of the FSAR were reviewed against the applicable portions of the E0Ps. As a result of this process, ten differences were identified; eight had been resolved and two remain open (i.e., ADS inhibit, and the use of nitrogen containment atmosphere dilution for combustible gas control).
The viewgraphs used for his presentation are included as Enclosure 3.
Following the licensee's presentation, the NRC staff reviewed the details of i
the licensee's evaluation process.
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Conclusion At the conclusiorhof the meeting, the NRC staff indicated that the licensee had conducted a thor'otg(evaluation of the above subject.
Furthermore, the staff indicated its agreement with the licensee's approach to the generic BWROG methodology for the res'olution of this issue for Hatch Nuclear' Plant, Units 1 and 2.
ORIGINAL SIGNED BY:
Kahtan N. Jabbour, Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosures:
1.
List of Attendees 2,
Meeting Agenda 3.
GPC Presentation cc W/ enclosures:
See next page DISTRIBUTION Docket-File NRC & Local PDRs PDll-3 R/F T. Murley/F. Miraglia,12G18 J. Partlow,12G18 S. Varga 1
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i Mr. W. G. Hairston, III Georgia Power Company Edwin I. Hatch Nuclear Plant l
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Mr. Ernest L. Blake, Jr.
M'.'. R. P. Mcdonald Shaw, Pittman, Potts and Trowbridge Executive Vice President -
2300 N Street, NW.
Nuclear Operations Washington, DC 20037 Georgia Power Company P. O. Box 1295 Mr. J. T. Beckham Birmingham, Alabama 35201 Vice President - Plant Hatch Georgia Power Company Mr. Alan R. herdt, Chief P. O. Box 1295 Project Branch #3 Birmingham, Alabama 35201 U. S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Mr. S. J. Bethay Atlanta, Georgia 30323 Manager Licensing - Hatch Georgia Power Company Mr. Dan H. Smith, Vice President P. O. Box 1295 Power Supply Operations Birmingham, Alabama 35201 Oglethorpe Power Corporation 2100 East Exchange Place Mr. L. Sumner Tucker, Georgia 30085-1349 General Manager, Nuclear Plant Georgia Power Company Charles A. Patrizia, Esquire Route 1, Box 439 Paul, Hastings Janofsky- & Walker Baxley, Georgia 31513 12th Floor 1050 Connecticut Avenue, NW.
Resident Inspector Washington, DC 20036 U.S. Nuclear Regulatory Commission Route 1, Box 725 Baxley, Georgia 31513 Regional Administrator, Region II 4
U.S. Nuclear Regulatory Commission 101 Marietta Street, NW. Suite 2900 Atlanta, Georgia 30323 i
Mr. Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street, SW.
4 Atlanta, Georgia 30334 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, Georgia 30334 Chairman Appling County Commissioners County Courthouse Baxley, Georgia 31513
, Conclusion At the conclusion of the meeting, the NRC staff indicated that the licensee had conducted a thorough evaluation of the above subject.
Furthermore, the staff indicated its agreement with the licensee's approach to the generic BWROG methodology for the resolution of this issue for Hatch Nuclear Plant, Units 1 and 2.
Wa/t J, b Kahtan N. Jabbour, Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II 1
Office of Nuclear Reactor Regulation
Enclosures:
1.
List of Attendees 2.
Meeting Agenda 3.
GPC Presentation cc w/ enclosures:
See next page 1
l
. -3 ENCLOSURE 1 May 12. 1993 NRC/GPC Meetina List of Attendees NRC GPC K. Jabbour
- 0. Vidal R. Frahm J. Heidt W. Long
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-l ENCLOSURE 2
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Aaenda for NRC/GPC Meetina 1
May 12. 1993 I.
INTRODUCTION NRC/GPC II.
GUIDANCE
SUMMARY
GPC.
o Review of FSAR against E0Ps, conflict identification o Methods for resolving conflicts III. OVERVIEW 0F HATCH E0Ps GPC IV.
DISCUSSION OF REVIEW PROCESS GPC'
- V.
DISCUSSION OF INDIVIDUAL CONFLICTS AND RESOLUTIONS
-GPC-o HPCI/RCIC suction source transfer o ADS inhibit O Standby liquid control initiation criteria i
o RCIC low pressure isolation setpoint o Use of containment atmosphere dilution for combustible gas control-o Operator actions for first 10 minutes of an accident o Deliberate lowering of water level
'o Torus temperature to initiate reactor depressurization o Secondary containment response to instrument line break l
0 Post accident water level indication VI.
CONCLUSIONS GPCjNRC i
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t HATCH 1 AND 2 V
E0P / LICENSING BASES DIFFERENCES P
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I. Introduction II. Guidance Summary III. Overview of Hatch E0P IV. Review Process P
V. i.isting-of conflicts and resolutions i
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Introduction o
Issue SER for Revision 4 to EPGs required licensees to assure that the E0Ps did not. viol' ate the.
licensing basis..
o BWROG established task force to resolve issue.
Develop plan to resolve issue.
Develop processes and criteria for utilities to use to identify and resolve conflicts.
Resolve the issue with NRC.
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II.
Guidance Summary o
Review FSAR against E0Ps (all sections) to identi fy conflicts.
o Where conflicts are found, resolve the conflict by:
Determining the conflict has no. impact on the licensing basis utilizing the licensing basis methodology.
Determining the conflict has no impact utilizing realistic methodologies / engineering judgment.
Revising the E0Ps or the licensing basis to resolve the conflict.
o Guidance discussed with NRC and tentatively approved.
Methodology appeared satisfactory.
Audit of Hatch results.
Staff to review ADS inhibit.
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.m III. Hatch E0P o
Developed consistent with revision 4
of NRC approved generic Emergency Procedure Guidelines.
Some deviations from the generic guideline-were taken.
All deviations documented, technically justified and reviewed by GE.
o Parallel Path Format o
Eight Flow Charts 2 Reactor Control 2 Primary Containment Control 1 Secondary Containment Control 3 Contingencies o
Supplemental Procedures Thirteen
- total, used to support activities initiated by the flow charts.
o Abnormal Procedures Not a part of E0P. -May be worked with E0P, but E0P actions take precedence.
15; IV.
Review Process o
Review criteria Is FSAR section affected by the E0P, i.e. does event result in an E0P entry condition?
Are there any differences between FSAR and E0P actions?
Does the difference constitute a conflict?
Reviewed transient and accident analyses sections o
(Primarily chapters 14 and 15 Unit I and 2 FSAR respectively and chapter 6 of both FSARs).
39 total events reviewed on Unit 1.
42 total events reviewed on Unit 2.
Sequence of FSAR events directly compared with E0P sequence.
o All other FSAR sections reviewed.
Required reading the text to
" hunt" for possible E0P / FSAR differences.
Sections dealing with plant systems were more likely to be affected by the E0P.
o Southern Nuclear provided an independent review of each section reviewed by Southern Company Services.
o Final review and results documented.
o Proposed resolution for each conflict was developed.
o GE independently verified these resolutions.
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-Differences and Resolutions o
Ten-total identified.
o GE was contracted to evaluate and resolve conflicts based on SNC proposed resolutions.
o Eight total have been resolved; two remain open.
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1.
Designed to auto transfer from CST to torus on high torus level.
E0P-overrides the transfer.
Proposed resolution:
i Design basis concern is the increased containment s
loads at-increased pool levels.
E0P allows continued suction from CST and utilizes
- other limits (i.e. SRV tail pipe level limit) to avoid excessive containment loads..
GE has provided concurrence, issue closed.
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ADS inhibit FSAR only provides for ADS inhibit for ATWS conditions.
E0P inhibits automatic initiation of ADS under all conditions.
1 Proposed resolution:
Adequate core cooling exists as long as water level is above TAF.
1 Initiating ADS at TAF ensures clad temperature remains below 22000F..
GE has provided concurrence.
The issue is not
- closed, however, because NRC actions are not complete.
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SBLC initiation criteria
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FSAR initiation criteria based on specific rod positions.
It also includes RPV water level criteria and suppression pool temperature criteria.
E0P uses Boron Injection Initiation Temperature limit coupled with an inability to shutdown the reactor.
Proposed resolution:
E0P criteria are more explicit' and bound the criteria in the FSAR.
E0P criteria are an improvement over the FSAR.
GE has provided concurrence, issue closed.
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RQIC low' pressure setpoint FSAR identifies the low. ' pressure isolation setpoint.
E0P overrides the low pressure isolation setpoint when RCIC is being.used for level control.
Proposed resolution:
I The Terry turbine used-in the RCIC system is capable of operating at; pressures much lower than the isolation setpoint without' damage.
GE has provided concurrence, issue closed.
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Use of-NCAD for-combustible gas ~ control.
FSAR pressurizes' Primary Containment'(PC) with NCAD to dilute oxygen and keep gases below the. flammable concentrations.
Allows PC pressure to increase to.
30-PSIG before. venting is initiated.
E0P _ strategy is a feed and bleed with ' nitrogen to maintain oxygen and hydrogen concentrations below flammable limits without pressurizing PC.
Proposed resolution:
BWROwnersGrouphascontractedwithGEanUOEIto.
evaluate the issue for'a generic resolution.
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6.
Operator actions within first 10 minutes of an accidentt FSAR states that in first.10 minutes following. 'an accident, operator actions are not'necessary..
E0P' assumes operator enters the E0P rapidly.
Proposed resolution:-
Operator actions mitigate the accident and are an additional margin of safety beyond that assumed'in the FSAR.
4 GE has provided concurrence,. issue closed.
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Deliberate lowering of water level to below TAF for an ATWS event.
Tech Specs require maintaining RPV water level above TAF at all times.
E0P permits lowering water level to as low as 28 inches below TAF as a means of reducing power for an ATWS.
Proposed resolution:
E0P instruction to lower water level i s beyond design basis of FSAR and Tech Specs.
With water level lowered to 28 inches below TAF, PCT does not exceed 1500oF and adequate core cooling is maintained.
GE has provided concurrence, issued closed.
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8.
Torus Temperature to initiate a reactor depressurization.
Unit 1 FSAR protection sequence diagrams indicate.
that RPV depressurization -is. begun when ' torus.
temperature is approximately 1300F.
E0P utilizes the Heat Capacity Temperature limit to determine when depressurization is required.
Proposed resolution:
E0P limits provide ample protection from failure of' the PC or equipment necessary for' safe ~ shutdown of.
the plant.
This is consistent with the FSAR purpose.
l GE has provided concurrence, issue closed.
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Secondary Containment response to instrument line break.-
FSAR states that Maximum Safe Operating Temperature-for any area :in the'. Secondary Containment is not:
exceeded for an unisolable instrument line. break outside containment.
No analysis exists however, to showJ that for the same
- break, E0P Maximum Safe' Water Levels or.
radiation levels will_not be exceeded.-
Proposed resolution:
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E0P places the plant in a safe condition by-using j
normal shutdown procedures prior.to-a Maximum Safe l-limit-being exceeded.
The..EOP will. initiate an-emergency ' depressurization if Maximum ~ Safe limits 3
are exceeded in more-than one: area. this is beyond
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the plant design basis.
GE has-provided concurrence, issue closed.
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10.
Water level indication FSAR demonstrates adequate core cooling for a DBA by reflood of the reactor core to a level at' the TAF-inside-1 the core shroud.
PRV level instruments may register a level lower than:
TAF,. in which case the. operator.is told'to flood the l
primary containment, an evolution not assumed by the FSAR.
Proposed resolution:
Differences. justified by. assessing realistic off-site-dose consequences for the 'DBA with~EOP ' actions.. The-1 realistic source term for a'.DBA is minimal, so-th'e j
radioactivity _ release from flooding andLLventingLthe
.j containment:is within licensing basis limits.
j GE has provided. concurrence;; issue closed.
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