ML20056F419

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Provides Staff Review Comments on GIs Re ABWR Design.Advises That GE Has Not Sufficiently Addressed,In Revised Ssar mark-ups,all Comments & Concerns Previously Provided by Staff
ML20056F419
Person / Time
Site: 05200001
Issue date: 08/12/1993
From: Borchardt R
Office of Nuclear Reactor Regulation
To: Marriott P
GENERAL ELECTRIC CO.
References
REF-GTECI-MI, REF-GTECI-SC, TASK-***, TASK-OR NUDOCS 9308270195
Download: ML20056F419 (15)


Text

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j@ M%g y[f a P UNITED STATES

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 1

l August 12, 1993 k . . . . . .o Docket No.52-001 Mr. Patrick W. Marriott, Manager Licensing & Consulting Services GE Nuclear Energy 175 Curtner Avenue i San Jose, California 95125

Dear Mr. Marriott:

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SUBJECT:

STAFF REVIEW COMMENTS ON GENERIC ISSUES RELATED TO THE ADVANCED B0ILING WATER REACTOR (ABWR) DESIGN On July 21, 1993, we transmitted a status of our review of various GE Nuclear Energy (GE) submittals (letters of April 30, May 4, May 18, and July 2,1993, and a facsimile on July 8, 1993) on unresolved safety issues (USIs) and generic safety issues (GSIs) for the ABWR. This transmittal also included a summary of the staff's questions and concerns for a number of issues that were discussed during four conference calls and which GE was requested to address.

In response to interactions with the staff on USIs and GSIs, GE has provided revised standard safety analysis report (SSAR) mark-ups for a number of USIs and GSIs in two additional submittals on July 15 and 26,1993. Since our '

July 21, 1993, transmittal of questions and concerns for a number of issues, the staff has completed its review of the July 15 submittal and performed a partial review of the July 26 submittal. (Our review of the July 26 submittal should be completed in the near future.)

Our review since July 21 has found that GE has not sufficiently addressed, in the revised SSAR mark-ups, all of the comments and concerns we previously provided. Another iteration of SSAR mark-ups is necessary for Issues A-10, B-5, C-8, 89, and 113. We note that GE still has not provided revised SSAR mark-ups for four issues (A-9, A-44, B-61, 105) that require mark-ups based on the resolution of related ABWR open items.

l The staff has also identified discrepancies in Table 19B.1-1, many of which l were highlighted in our July 21 letter, that GE needs to reconcile. Since l l July 21, the staff has completed its initial review of 10 task action plan  !

items and new generic issues under the cognizance of the Plant Systems Branch. '

We have identified that revised SSAR mark-ups are needed for 7 of those issues (A-17, C-17, 25, 51, 82, 143, 153). .

In the area of Three Mile Island (TMI) Action Plan items, we have requested input from the responsible technical review branches on concerns or questions that GE needs to address to achieve closure of all unresolved TMI items. We 1 have completed the initial review of three TMI items (SSAR mark-ups submitted )

by GE on May 18, 1993) which were not addressed in the staff's draft final I safety analysis report for the ABWR, and we are preparing a status matrix for TMI Action Plan items.

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Mr. Patrick W. Marriott August 12, 1993 A summary of the review of task action plan items, new generic issues, and human factors issues as of August 6,1993, is summarized in Enclosure 1.

Enclosure 2 details the concerns identified during our USI-GSI review activi-ties since July 21 which need to be addressed. Again, please be aware that GE's complete resolution of the staff's concerns and prompt turnaround of mark-ups and provision of other requested information is essential to avoid needless reiterations on the same issues and to maintain the ABWR review schedule.

Should you have any questions or desire further discussion'on the information >

provided in this letter, please co'ntact either Melinda Malloy, (301) 504-1178 or Chet Poslusny, (301) 504-1132.

Sincerely, R. W ,ktingDirector Standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal i Office of Nuclear Reactor Regulation

Enclosures:

1. Status of ABWR USI-GSI Review as of 8/6/93
2. Staff Comments on Proposed Resolutions of Generic
  • Issues for the ABWR as of 8/4/93 cc w/ enclosures:

See next page Distribution w/ enclosures:

Docket File PDST R/F DCrutchfield RBorchardt PDR JNWilson MMalloy CPoslusny  ;

SNinh SKoenick DTerao, 7H15 HBrammer, 7H15 DThatcher, 7E4 JLyons, 801 WBurton, 801 MRubin, 8E23 GThomas, 8E23 RGramm,'9Al RCorreia, 10A19 TPolich, 10A19 l MChiramal, 8H7 JStewart, 8H7 CGoodman, 10D24 REmch, 9H15 JLee, 10D4 RDube, 9D24 FYoung MWohl, 11E22 MFinkel stein,15B18 )

Distribution w/o enclosures: -

TMurley/FMiraglia PShea WRussell JMoore, 15B18 ATGody, Jr., 17G21 ACRS (11) JWiggins, 7D26 GBagchi, 7H15 AThadani/MVirgilio, 8E2 CBerlinger, 7E4 RPerch, 8H7 CMcCracken, 8D1 l

i ERossi/RZimmerman,9A2 RJones, 8E23 WBeckner, 10E4 AEl-Bassioni, 10E4 GZech, 10A19 JWermiel, 8H7 REckenrode, 10D24 LCunningham, 10D4 .

BBoger/CThomas,10H5 PMcKee, 9D24 BGrimes, 11E4 i FCongel/EButcher,10E2 CGrimes, 11E22 RLipinski, INE -(Rockvill , NLOO7 0FC: LA:PDS R PM:PDST:ADAR PM:PDST ADAR - -

ADAR (A) DST:ADAR NAME: PShea MMalloy:tf'4t CPoslu[nP W n RB 1ardt ,

DATE: 08/(l/ 08/,1/93r 08/n /93 08/ /93 08 g 93 0FFICIAL RECORD COPY: GI-LTR2.MM

4 Mr. Patrick M. Marriott Docket No.52-001 General Electric Company cc: Mr. Robert Mitchell Mr. Joseph Quirk General Electric Company GE Nuclear Energy 175 Curtner Avenue General Electric Company San Jose, California 95125 175 Curtner Avenue, Mail Code 782 San Jose, California 95125 Mr. L. Gifford, Program Manager Regulatory Programs Mr. Raymond Ng GE Nuclear Energy 1776 Eye Street, N.W.

12300 Twinbrook Parkway Suite 300 Suite 315 Washington, D.C. 20006 Rockville, Maryland 20852 Director, Criteria & Standards Division Office of Radiation Programs U.S. Environmental Protection Agency 401 M Street, S.W.

Washington, D.C. 20460 Mr. Sterling Franks  ;

U.S. Department of Energy NE-42 Washington, D.C. 20585 Marcus A. Rowden, Esq.

Fried, Frank, Harris, Shriver & Jacobson .

1001 Pennsylvania Avenue, N.W. l Suite 800 Washington, D.C. 20004  :

Jay M. Gutierrez, Esq. I Newman & Holtzinger, P.C.

1615 L Street, N.W.

Suite 1000 Washington, D.C. 20036 Mr. Steve Goldberg Budget Examiner 725 17th Street, N.W.

Room 8002 Washington, D.C. 20503 i Mr. Frank A. Ross U.S. Department of Energy, NE-42 Office of LWR Safety and Technology 19901 Germantown Road Germantown, Maryland 20874

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. STATUS OF ABWR USI-GSI REVIEW AS OF 8/6/93 (Task Action Plan items, New Generic Issues, and Human Factors issues Only)

Issues that do not need further GE input -- 20 l Branch issues f

i ECGB A-1, A-13, A-40, #,-42, B-55, B-63,15, 29, 78, 86, 87,103,

! 118 l SRXB 23 i EELB A-35 HICB 45,151 (Note: Issue 120 incorrectly listed in status dated 7/13/93 contained in 7/21/93 letter from J.N. Wilson to P. Marriott)

SPLB A-36,121,124 Issues for which GE needs to provide revised SSAR mark ups -- 13 Branch issues ECGB A-10, B-5, C-8, 89,113 HICB A-47 SPLB A-17, C-17, 25, 51, 82,143,153 Issues for which resolution or GE submittal of revised SSAR mark-up is on hold pending resolution of other related ABWR open items (issue mark-up will need to be consistent with open item resolution) -- 4 Branch issues EELB A-44 SRXB A-9,105 OTSB B-61 i

i Enclosure 1 1 i

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.) 1 STATUS OF ABWR USI-GSI REVIEW AS OF 8/6/93 (Task Action Plan items, New Generic issues, and Human Factors issues Only)

Issues for which staff review of revised GE SSAR mark-up not yet complete -- 17 Branch issues EELB A-25, B-56,128 SRXB A-31, 40 RPEB 75,145  :

HICB 67.3.3, 142, 120 i (Note: Issue 151 incorrectly listed in status dated 7/13/93 contained in 7/21/93 letter from J.N. Wilson to P. Marriott)

HHFB B-17, HF 1.1, HF 4.4, HF 5.1, HF 5.2 ,

PRPB 155.1 PSGB A-29 issues not ready for discussion with GE -- 16 ,

Branch issues 2 SPLB A-7, A-8, A-24, A-36, A-39, A-48, B-10, B-36, B-66, C-1,

! C-10, 57, 83,106,121,124 Review Branch Kev:

ECGB - Civil Engineering and Geosciences Branch EELB - Electrical Engineering Branch SPLB - Plant Systems Branch RPEB - Performance and Quality Evaluation Branch HICB - Instrumentation and Controls Branch HHFB - Human Factors Assessment Branch PRPB - Radiation Protection Branch PSGB - Safeguards Branch OTSB - Technical Specifications Branch E

GE submitted revised SSAR mark-ups for alllisted issues on July 26,1993.

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STAFF COMMENTS ON PROPOSED RESOLUTIONS OF

GENERIC ISSUES FOR THE ABWR AS OF 8/4/93 '

l l Generic issues Assigned to the CivilEngineering and Geosciences Branch ,

l (ECGB)

Issue A-10 (GE submittals dated 4/30/93, 5/18/93, and 7/15/93, SSAR Section 19B.2.6):

GE needs to propose inservice inspection (ISI) requirements for the welded '

double sleeve design that are consistent with Table 2 (p.- 15) of NUREG-0619 for staff review, i.e., covering the type of inspections and frequency of inspections. The statements in the GE resolution that routine' ultrasonic inspection of the inside nozzle blend radius section and that the planned ISI  :

program is as outlined in the ASME Boiler and Pressure Vessel Code Section l XI are insufficient. .

L lt is recognized that the specific ABWR design is not covered in Table 2 of NUREG-0619. However, the table note indicates that ISI requirements for other designs should be submitted to the staff for review. Sufficient infor-mation on the configuration, materials of construction, and performance l

characteristics of the welded thermal sleeves should be provided with the proposal to allow facilitate evaluation.

1 Issue A-40 (GE submittals dated 4/30/93 and 7/15/95,'SSAR Section 198.2.14):

No additional concerns.

Issue B-5 l

(GE submittals dated 4/30/93, 7/15/93, and 7/26/93, SSAR Section 19B.2.61): ]

1. The GE resolution references ACI 349 (1990), which does not exist. I The latest edition of ACI 349 is 1985, although there is a 1990 Supple-ment.
2. Although the GE acceptance criteria indicates that the design of safety- _

related concrete structures shall meet the ductility requirements of ACI 349, as endorsed by Regulatory Guide (RG) 1.142, the resolution states that the ABWR design is based on ACI 349 and does not address compliance with RG 1.142.

Enclosure 2

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4 Issue B-55 l (GE submittals dated 4/30/93 and 7/15/93, SSAR Section 198.2.22):

No additional concerns, issue C-8 1

(GE submittal dated 7/15/93, SSAR Section 19B.2.61.1): I The ABWR design does not incorporate a main steam line isolation valve leakage control system and, therefore, deviates from RG 1.96. The ABWR l provides an alternative design approach, however, which the staff has reviewed. It is not clear from reading this SSAR Section 198.2.61.1 why GE believes it is acceptable for the ABWR design to not meet RG 1.96.

In addition to the information already provided, GE's resolution should also 'l explicitly address its departure from RG 1.96 and express the ABWR design in terms of an acceptable alternative approach. l l

l Issue 29 (GE submittals dated 4/30/93 and 7/15/93, SSAR Section 198.2.62):

No additional concerns. j issue 78 (GE submittals dated 4/30/93 and 7/15/93, SSAR Section 19B.2.39):

No additional concerns. I Issue 89 l

(GE submittals dated 4/30/93 and 7/15/93, SSAR Section 19B.2.43):

Provide more details on the analyses done resulting in the conclusion that pipe-clamp induced stresses are negligible and, therefore, do not warrant explicit consideration for the ABWR. It is not clear that the sample calcula-tions for stiff pipe clamps on BWR main steam and recirculation piping systems (discussed in the GE acceptance criteria) can be extrapolated to the ABWR. GE should provide information on the criteria or parameters applied

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i Issue 89. continued )

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to justify this extrapolation. Also, GE needs to address the margins of the

! calculated stresses (which should include the increase in stress due to stiff pipe clamps) with respect to the ASME Code allowables.

Issue 113 l

l (GE submittals dated 5/4/93, SSAR Section 198.2.47 and 7/2/93 and 7/15/93, SSAR Section 19B.2.64):

1. The GE resolution is not clear regarding whether large bore hydraulic snubbers (LBHSs) are to be used only in piping systems applications.

Will the ABWR use LBHSs in other than piping applications? If so, provide information regarding the number to be used in each expected

! application. If not, clarify the wording of the GE resolution in SSAR Section 19B.2.64.

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2. SS AR 3.9.3.4.1(3), referenced in the GE resolution, appears to provide i

only one element specifically addressing dynamic qualification testing of LBHSs used as piping restraints. Were other elements in this SSAR section intended to be applicable to LBHSs? Also, if LBHSs are to be used in other than piping applications (reference question above), GE should revise the SSAR to indicate this and so it is clear which dynamic testir;g requirements are applicable to LBHSs that are used in applica-tions other than other than piping restraints.

Generic issues Assigned to the Plant Systems Branch (SPLB) (PARTIAL) l issue A-17 (GE submittal dated 5/18/93, SSAR Section 198.2.59):

1. GE should indicate which of the interaction incidents involving flooding or water intrusion from internal plant sources referenced in NUREG-i 1174 they have addressed and what ABWR design features provide l

protection against adverse system interactions due to the effects of flooding and water intrusion. GE needs to identify and justify the selection of equipment with shields or that are assumed to be drip proof as protection against water intrusion.

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I Issue A-17, continued

2. GE needs to provide information about the measures taken in the ABWR i design to counter susceptibility of the plant to water flow along unantic-ipated paths that may result in failing important equipment (or panels).

This information should identify protected equipment and justify its

selection.
3. GE should tie this resolution into the probabilistic risk assessment (PRA) insights on flooding.

Issue A-36 (GE submittal dated 5/4/93, SSAR Section 198.2.12):

No questions or concerns.

Issue C-17 (GE submittal dated 4/30/93, SSAR Section 198.2.29):

The SSAR Section 198.2.29 mark-up currently states that the acceptance criteria for resolution of C-17 is that there is [ sic] no current criteria. The GE acceptance criteria should be revised to state that there are no current criteria for acceptability of radwaste solidification agents and that it will be the responsibility of the COL applicant to propose a solidification agent for staff review and approval. The proposed resolution should be revised to capture the COL applicant action item in this regard identified in SSAR Section 11.4.3.

Issue 25 l

(GE submittal dated 4l30/93, SSAR Section 198.2.32):  !

GE's proposed resolution describes two ABWR design features that will  ;

provide protection against an event involving the slow loss of control air pressure in the scram air header that can allow some of the scram accumula- l tors to leak to the reactor. GE should provide references to the SSAR l sections where these specific features are discussed in more detail. I l

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(GE submittal dated 4/30/93, SSAR Section 19B.2.35):

1. GE's proposed resolution should indicate which of stated ABWR require-ments for plant cooling water systems are COL applicant action ite'ms.
2. What means will be used in the ABWR to detect. leakage across the heat exchangers?

Issue 82 (GE submittal dated 4/30/93, SSAR Section 198.2.63):

1. GE's proposed resolution should indicate the specific ABWR design features to prevent draining of the spent fuel pool.  ;
2. In its evaluation of issue 82 in the context of the EPRI Utility Require-ments Document For Evolutionary Plant Designs (NUREG-1242), the i staff concluded that the use of low-density storage racks for, as a minimum, the most recently discharged fuel, was justified by a favorable valuelimpact ratio (reference Section 3.2.20 of Appendix 18). The j evaluation indicated that the staff would expect the FDA/DC applicant' l to submit a design that incorporates this feature. Discuss whether GE i has incorporated this feature in the ABWR design? If not, provide a justification as to why this it is not necessary to do so.  ;

I issue 121 j l

(GE submittal oated 4/30/93, SSAR Section 19B.2.50):

No questions or concerns.

Issue 124 (GE submittal dated 4/30/93, SSAR Section 19B.2.51):

No questions or concerns. l l

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issue 143 l (GE submittal dated 4/30/93, SSAR Section 19B.2.54):  ;

GE's reiteration of the possible solutions identified in NUREG-0933 as the  :

acceptance criteria is not appropriate. Since a resolution to this issue has not yet been identified by the staff, GE should propose acceptance criteria that can be applied to the ABWR, and then, address the ABWR design fea-tures that satisfy the proposed acceptance criteria in the GE resolution. In j developing appropriate acceptance criteria, the staff recommends that GE I concentrate on the historical background arid safety significance' discussions i

! I in NUREG-0933.

hsue 153 )

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(GE submittal dated 4/30/93, SSAR Section 19B.2.57): l 1

GE's resolution needs to:

o elaborate on the potential causes of reactor service water (RSW) system j l

degradation and the design features for protection against system performance degradation and associated failure modes.

  • specifically state for what the COL applicant will be responsible, includ-ing assessing potential RSW failure modes and their associated contribu-tions to the core damage frequency and the dominant accident sequenc-es. Provide a specific COL applicant action item reference, Other Generic Issues Not Assigned to Specific NRR Review Branches i

Issue 73 l

l (GE submittal dated 7/2/93, SSAR Section 19B.2.37.1):

> 1 The staff's 7/21/93 letter informed GE that Appendix B of NUREG-0933 shows.this issue is not applicable to BWRs and asked GE to explain why it is important to be addressed for the ABWR. GE has not provided an explana-tion, but the staff noted that issue 73 is no longer included in the version of the Safety issues Index (Table 198.1-1) transmitted on 7/26/93. GE should explicitly inform the staff whether it is withdrawing this issue from further staff review and evaluation.

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Miscellaneous issues (GE submittal dated 7/26/93, Table 198.1-1):

1. NRC priority for issue B-17 is incorrectly shown as " Resolved." The correct priority is " Medium." The SSAR subsection is shown as Appen-dix 18A (which not sufficiently explicit). SSAR Section 198.2.20 (submitted on 7/26/93) also addresses issue B-17. Which is correct? l i
2. Title of Issue B-36 incorrectly includes " Absorption" instead of )

" Adsorption." l

3. NRC priority for issue B-55 is incorrectly shown as " Resolved." The correct priority is " Medium."
4. NRC priority for issue B-56 is incorrectly shown as " Resolved." The l correct priority is "High." l
5. NRC priority for issue 57 is incorrectly shown as " Resolved." The correct priority is " Medium."
6. NRC priority for issue 78 is incorrectly shown as " Resolved." The correct priority is " Medium."
7. NRC priority for issue 83 is incorrectly shown as "Near Res." The i correct priority is "Possible Res "
8. NRC priority for Issue 120 is incorrectly shown as " Medium." The correct priority is " Resolved." Since 120 was resolved with no new requirements, it should be moved to the section of the table " Issues Resolved With No New Requirements."
9. Since issue 121 was resolved with no new requirements, it should be moved to the section of the table " Issues Resolved With No New Requirements."
10. Title of Issue 143 incorrectly includes "and Room Cooling." This incorrect information should be deleted.

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11. NRC priority for issue 145 is incorrectly shown as " Resolved." The correct priority is "Res. Available." The issue title is incorrectly shown.

It should be corrected to " Improve Surveillance and Startup Testing Programs."

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Miscellaneous issues, continued

12. Title for issue 151 is incorrectly shown. It should be corrected to

" Reliability of Recirculation Pump Trip During An ATWS." Since 151 ,

was resolved with no new requirements, it should be moved to the section of the table " Issues Resolved With No New Requirements."

13. NRC priority for issue 155.1 is incorrectly shown as "Near Res." The correct priority is "Res. Available."
14. Title for issue HF 5.2 should show " Controls" instead of " Control."
15. Title for issue A-17 is incorrectly shown. It should be corrected to

" Systems interaction in Nuclear Power Plants."

16. The spe!!!ng of the word " Vulnerability" in the title of Issue A-29 needs to be corrected.
17. Correct " Bases" to " Basis" in the title of issue 82.

TMI Action Plan items Assigned to the instrumentation and Controls Branch (HICB) (PARTIAL.)

1.D.5(2) l (GE submittal dated 5/18/93, SSAR Section 19B.2.65):

i l No questions or concerns.

l II.K.1(23)

(ABWR SSAR Section 1 A.2.21, Amendment 27):

No questions or concerns.

II.K .3(27) -

l (GE submittal dated 5/18/93, SSAR Section 19B.2.71):

No questions or concerns. l l  !

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O Miscellaneous Three Mile Island (TMI) Action Plan items (PARTIAL.)

1. In its 7/21/93 letter, the staff indicated that the SSAR needs to provide a j discussion which supports the status of the following TMI Action Plan items presently identified in the GE Safety issues Index (SSAR Table 198.1-1) for

" COL Applicant:"

1.A.1.1 1.A.1.2 1.A.1.3 1.A.2.1(1) 1. A.2.1 (2) 1. A.2.1 (3) l.A.2.3 1. A.2.6(1 ) 1.A.3.1 1.A.4.1(2) 1.C.2 l.C.3 4 l.C.4 l.C.6 l.C.7 l.C.8 II.B.4 ll.J.4.1 lil. A.1.1 (1 ) lil. A.2.1 (1 ) lli. A.2.1 (2) lil. A.2.1 (3) lli. A.2.1 (4) lil. A.2.2 lil. A.3.3(1 ) lli. A.3.3(2)

J GE's 7/26/93 submittal added 3 more items to this list [l.C.1(1), l.C.1(2),

and ll.E.1.3] and did not address the staff's comment.

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GE indicates in its latest mark-up of SSAR Sectio'n~~19B.3.1'~that ths COL ,

applicant shall provide resolutions for the issues identified as " COL Appli-cant"1n Table 198.1-1, consistent with the format discussed in SSAR Section 19 . (that is, an evaluation that includes an issue summary, acceptance critena, technical resolution, and references). This would be appropriate for items thattave not yet been resolved by the NRC. However, V

each of these items has been resolved in view of this, it is the staff's position that GE can and should explain -what the COL applicant is expected L to do in order to meet the intent of the item resolution. There are several examples of this approach in the COL license information of SSAR Section

( 19A.3. Where GE believes this is not feasible, GE needs t'o' provide an

\ explanation for such TMI items why GE cannot resolve the itemk4h N design stage.

2. The staff's 7/21/93 letter indicated that several TMI items [l. A.1.4, l.C.1(1),

l.C.1(2), l.C.1(3), l.D.1, ll.E.1.3] appeared to be missing from the GE Safety issues index (SSAR Table 19B.1-1). The staff requested GE to provide a SSAR reference in SSAR Table 198.1-1 and a SSAR discussion for items that were not already addressed in the SSAR.

GE's response in its 7/26/93 submittal was to list 3 items [1.C.1(1). l.C.1(2), -

II.E.1.3] for COL applicant action (see discussion above) and to provide other SSAR references for I.A.1.4 and I.D.2.-GEiiueds tu adUrss1he commen{

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j above for the TMI items indicated for COL-epplicanteckn. GE has

! indicated that 1.A.1.4 is addressed in SSAR Appendix 18E. GE needs to '

provide a more specific SSAR reference for this item.

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3. Correct "all" to "All" in the title of Issue 1.F.2(3).
4. Correct SSAR Subsection from "1. A.2.4" to "1 A.2.4" for I.G.1.
5. Correct SSAR Subsection from "19.A.2.1" back to "19A.2.21" for ll.B.8.

l 6. GE's 5/18/93 submittal provided SSAR Section 198.2.71 addressing II.K.3(27). The Safety issues index provided on 7/26/93 now refers to Section 1 A.2.21. What's the correct reference? If the latter reference is

! correct, what is GE's disposition of SSAR Section 198.2.717

7. GE's 5/18/93 submittal provided SSAR Section 198.2.72 addressing l

lil.D.3.3(1). The Safety issues index provided on 7/26/93 now refers to i

Section 19A.2.39. What's the correct reference? If the latter reference is

! correct, what is GE's disposition of SSAR Section 198.2.72?

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8. GE's 5/18/93 submittal provided SSAR Section 198.2.73 addressing ill.D.3.3(2). The Safety issues Index provided on 7/26/93 now refers to Section 19A.2.39. What's the correct reference? If the latter reference is correct, what is GE's disposition of SSAR Section 19B.2.73?

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