ML20056G040

Requests Licensee Views on Completeness of Process for Assessing EOPs Against Current Licensing Basis,Per from WT Russell of NRC

ML20056G040
Person / Time
Issue date:	08/17/1993
From:	Thadani A Office of Nuclear Reactor Regulation
To:	England L BWR OWNERS GROUP, GULF STATES UTILITIES CO.
References
NUDOCS 9309010207
Download: ML20056G040 (2)

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UNITED STATES

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j NUCLEAR REGULATORY COMMISSION j

e WASHINGTON, D.C. 20h0001 g

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August 17, 1993 i

i Mr. L. A. England, Chairperson

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BWR Owners' Group b

i c/o Gulf States Utilities

-l River Bend Station North Access Road Saint Francisville, LA 70775

Dear Mr. England:

i

Subject:

Differences Between the Emergency Operating Proceduras and the l

Licensing Basis

Reference:

Letter to Robert D. Binz, IV, Chairman, BWROG from William T. Russell, USNRC, dated May 12, 1992.

In the above referenced letter, the NRC staff gave preliminary approval to the BWR Owners Group (BWROG) methodology, attached as slides to Enclosure 1, for reconciling differences between the plant emergency operating procedures (EOP) i and the plant licensing basis in the updated final safety analysis report (UFSAR).

It was also stated that the NRC would give final approval after performing an audit of the Hatch validation results using the BWROG methodology.

i In a meeting with Georgia Power Company on May 12, 1993 (meeting minutes,

), the staff performed the audit of the Hatch Nuclear Plant i

validation results that used the BWROG methodology for assessing differences between the E0Ps and UFSAR licensing basis. The plant validation results j

yielded ten E0P/UFSAR differences. Eight have been resolved, to the licensee's satisfaction, and two remain open. The staff found the~ licensee's l

assessment for finding these differences using the BWROG methodology and their j

approach to resolving them acceptable for the Hatch Nuclear Plant.

The NRC therefore agrees that the BWROG methodology for assessing differences between E0Ps and UFSAR is acceptable. We also find that the licensee performed a thorough assessment in finding these differences using the BWROG j

methodology. However, this acceptance should not be considered as approving l

the licensee's resolution of any of the specific issues identified by

?

. application of the methodology.

Individual plants should keep their j

assessments for E0P/UFSAR differences as a part of-their plant records.

Recent NRC audits have found that most of the new design bases and commitments i

made to the NRC after licensing to address generic letters, bulletins, enforcement actions and licensee event reports are not included.in the FSARs.

Although the BWROG and Hatch have done a complete assessment of the UFSAR/EOP differences there could be relevant information not addressed or reconciled by this process. Accordingly, we request your views on the completeness of your process for assessing the E0Ps against the current licensing basis.

8P 1888K Zi88siss NRC FIE CENTER C8PY N

F PDR-

i Mr. L.A. England August 17, 1993 i

Please contact R. Frahm (301-504-2866), if you have any questions or comments regarding this letter.

Sincerely,

( 9 Ashok Thadani, Director i

Division of Systems Safety & Analysis

.l Office of Nuclear Reactor Regulation

Enclosures:

1 t

1.

Letter to William T. Russell, USNRC j

from Robert D. Binz IV, Chairman, BWROG, dated April 12, 1992.

2.

Summary of May 12, 1993, meeting on the differences between the emergency 1

operating procedures and the licensing

basis, r

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ENCLOSURE 1 BlDR ou;uens enoug

--=ea c o Pubhc Service E6ectric 5 Gos Com Hope Creek Gerwer.mg Stotion BW OG-9203/4 P.O. Box 236. Moil Code N51

• Hancocks Bnoge. NJ 08058 April 21, 1992 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Station 12G18 VsshinEton DC 20535 Attention: William T. Russell, Associate Director Inspection and Technical Assessment

Subject:

EMERGENCY OPERATING PROCEDURES /1,ICENSING BASIS DITTERENCES i

Members of the BVR Owners ' Group Emergency Procedure Guidelines (EPG) Task Force met with you and members of your staff on September 17, 1991 to review the process the task force has developed to identify and resolve the differences between the Emergency Operating Procedures (EOPa) and the Licensing Basis.

Enclosed are the slides presented by the BVROG at the referenced meeting which describe the issue and the proposed resolutien l

process.

At the meeting NRC staff attendees expressed general concurrence with the approach.

Documentation of NRC concurrence would help facilitate effective and consistent implementation of this approach by our member utilities.

Therefore, we request that the NRC provide their written evaluation of the proposed BVROC process for addressing EOP/1.icensing Basia differences.

As you are aware the 1988 Safety Evaluation Report for EPC Rev. 4 included the following guidance, "Each BVR licensee who wishes to use the revision of the EPG should assure that the EPGs will not impact its licensing bacis."

The initial portion of the BVROG resolution process (see attached slides) consists ;

of determining if applicable E0P actions differ from UFSAR procedures / actions for each UFSAR event.

10CFR$0.59 methodology is initially employed to assess the differences based on deterministic analyses.

Since the EPGs were developed to cover a much broader scope of events than those covered in the UFSAR and were based on realistic analyses, it is possible thst some EOP/

1.icensing Basis differences will arise that are appropriate to justify based

-on the EPC developmental criteria. Therefore, the proposed resolution process provides an option to use realistic analyses where appropriate to justify the differences.

In the referenced meeting NRC attendees concurred with the use of realistic analyses and engineering judgement as described in the attached slides. Your written concurrence with the overall approach is requested.

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D William T. Russell Bk' ROC 92034 April 21, 1992

.Page 2 The proposed resolution process for EOP/ Licensing Basis differences is responsi.e to the intent of the referenced SER guidance.

It also should help minimize the need for plant specific deviations from EPG Rev. 4 to resolve differences with the Licensing Basis.

Please contact J. Heidt (EPC Task Force Chairman) at (205) 877-7316 if you have any questions or comments regarding this request.

We look forward to your expeditious reply to f acilitate the ongoing implementation of EPG Rav. 4 by member utilities.

Regards.

I R, D. Binz IV, Chairnan Bk'R Owne rs' Group EXEC 03/RDB/CLT/ds i

l Enclosure CL Tully, BVROC Vice Chairperson cc:

AC Thadani, NRC BT k'illiamson, Energency Procedures Co==ittee Chairman JD Heidt, EPC Task Force Chairman LS Cifford, CE-RCK SJ Stark, GE PC Marriott, CE Bk"ROG Primary Representatives Emergency Procedures Committee Executive Oversight Co==ittee NRC Deccent Control Branch d

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EMERGENCY OPERATING PROCEDURES / LICENSING BASIS DIFFERENCES i

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j A PRESENTATION BY THE

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BWROG EPG TASK FORCE i

l SEPTEMBER 17, 1991 ROCKVILLE, MD

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SJS4T/091791 l

-::.-iL-,

l EMERGENCY OPERATING PROCEDURES / LICENSING BASIS DIFFERENCES 1

TOPICS i

BACKGROUND

r --

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HATCH VALIDATION RESULTS COMPARISON WITH LICENSING BASIS CONCLUSIONS SJS4T/091791 1

BACKGROUND

._---. + = _. :.. e

=2 -. :. - = +c=: -. = -. -

ORIGINS OF BWROG EMERGENCY PROCEDURE GUIDELINES LESSONI.EkRNIDiR6MYdI (NUREG 07-37-SUPPLEMENT lb=-

SYMPTOM ORIENTED BASED ON REALISTIC ANALYSES IMPLEMENTED BY ORDER I

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l SJ54T/091791 2

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RELATIONSHIP BETWEEN E0Ps AND LICENSING BASIS 3

LICENSING BASIS. _.

EVENT PATH r

k NOTES:

1. RANGE OF POTENTIAL EVENT PATHS C0VERED BY E0Ps REPRESENTED BY MULTIPLE BRANCHING PATHS

2. HIGHLIGHTED PATH REPRESENTS EVENT AS DESCRIBED IN UFSAR i

SJ53T/050291

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BACKGROUND (CONTINUED) l o

IDENTIFICATION OF CONCERN i

1988 SAFETY EVALUATION REPORT FOR EPG REY. 4 "EACH BWR LICENSEE WHO WISHES TO USE THE REVISION OF THE EPG SHOULD-ASSURE THAT THE-EPGs WILL NOT "

IMPACT ~ITS LICENSING BASIS" l

o DISCUSSIONS OF RESOLUTION OPTIONS (BWROG/NRC) i DIFFERENCES RATHER THAN CONFLICTS l

GENERAL IMPRESSION THAT EPGs GIVE APPROPRIATE BALANCED APPROACH

~

DIFFERENCES SHOULD BE IDENTIFIED DIFFERENCES SHOULD BE RECONCILED (JUSTIFY ACCEPTANCE OF DIFFERENCE OR CHANGE E0P/UFSAR)

REALISTIC ANALYSES CAN BE USED i

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SJS4T/091791 4-I

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BACKGROUND (CONTINUED) l l'

EPG TASK FORCE o

APPROVED JANUARY 1991 i

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STARTED WITH CHARTER END6RSED BY BWROG EXECUTIVE

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j OVERSIGHT COMMITTEE DEVELOP STRATEGIC PLAN FOR RESOLUTION OF ISSUE I

DEVELOPPROCES5WITHCRITERIk

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o RESOLUTION PROCESS DRAFTED FEBRUARY 1991 1

o DISCUSSION OF ISSUES WITHIN BWROG o

TRIAL VALIDATION

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REVIEW WITH NRC 1

4 SJS4T/091791 5

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RES~

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UFSRR EVENT i

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NO NO FURTHER-00 S V

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/ EVALURTION REQUIRED ENTRY ?

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YES' I

DO EOP RCTIONS NO EPRRT FROM UFSRr f

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CT10NS7 i

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RSSESS CONSEQUENCES 1

i OF E0P RCTIONS UPDRTE FSRR USING UFSRR METHODOLOGY (i.e. 50.SS) l

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um JUDGEMENT OR i

DETERMINISTIC RRE NO CONSEQUENCES MORE SEVERE?

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JUSTIFICATION RPPRORCH ESIRRSLE?

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TRKE ONE OF FOLLOVING EVALURTE EOP RCTIONS:

CONSEQUENCES ~USING---

~":-. 1) REVISE EDP*S REALISTIC RNRLYSIS

2) REVISE LICENSING BRSIS

3) OTHER?

O nERLISTIC ND CONSEQUENCES j

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ONSEQUENCE *

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YES p

NOTIFY NRC OF USQ RNO SEEK DEVELOP FURTHER JUSTIFICATION CONCURRENCE OF RERLISTIC RPPRDRCH

/N YES NRC NO CHRLLENGE NRC RCCEPTS?

f POSITION?

ND YES i

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LSSUE RESOLVED N/

UPDATE FSRR I

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HATCH VALIDATION i

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COMPREHENSIVE REVIEW OF FSAR AGAINST E0Ps l

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500 MANHOURS EXPENDED ON UNIT - 2.

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o 42 EVENTS (CHAPTER.15)-ANALYZED IN DETAIL: 7-a i

o ALL OTHER CHAPTERS AND APPENDICES REVIEWED - ------ -- -

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7 DIFFERENCES IDENTIFIED i

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t HATCH VALIDATION r==- =

HPCI/RCIC SUCTION TRANSFER

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FSAR STATES HPCI/RCIC SUCTION TRANSFERS FRON CST T0.

SUPPRESSION POOL ON HIGN~5UPPRESSION P0OL. LEVEL l

o E0P OVERRIDESTRANSFER IN-ALL CASES o

E0P PROVIDES FOR ASSESSNENT OF SUPPRESSION POOL HEAT" --

AND PRESSURE CAPACITY IN MAKING DECISIONS TO ISOLATE WATER SOURCES s

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NO UNREVIEWED SAFETY QUESTION.

CONTAINNENT LOADS

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ACCEPTABLE 1

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SJS4T/091791 9

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HATCH VALIDATION AUTOMATIC DEPRESSURIZATION SYSTEM J--

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FSAR DESCRIBES ADS AS FULLY-AUTOMATIC 5YSTEM WHICH CAN BE MANUALL1-INITIATED.0R OVERRIDDEN --

o E0P INHIBITS AUTOMATIC INITIATION LOGIC.

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E0P RECOGNIZES OPERATOR POSSESSES INFORMATION NOT AVAILABLE TO THE AUTOMATIC INITIATION LOGIC -

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PCT STILL MAINTAINED WELL BELOW 2200 F

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SJS4T/091791 10

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HATCH VALIDATION

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WATER LEVEL INDICATION i

o FSAR LOCA ANALYSIS DEMONSTRATES ADEQUATE CORE COOLING J

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i BASED UPON LEYEL RECOVERY INSIDE SHROUD o

E0P UTILIZES REACTOR-INSTRUMENTATION -70 DETERMINE - Cr: -

REACTOR WATER LEVEL RECOVERY

_. _- _ -.3. :_- c.

o E0P COULD LEAD OPERATOR INTO CONTAINMENT FLOODING WHEN ' ~ ~ ~

CORE IS ACTUALLY COVERED o

RESOLVE BY ASSESSING OFFSITE DOSE EFFECTS RESULTING l

4 FROM THE CONTAINMENT VENTING USING DOSE ASSESSMENT METHODOLOGY BASED UPON REALISTIC ASSUMPTIONS i

o NO FUEL DAMAGE, THEREFORE, CONSEQUENCES MAINTAINED WITHIN PART 100 f

i SJS4T/091791 11

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MATCH VALIDATION

.=.

OPERATOR ACTION c

o FSAR STATES N0 OPERATOR ACTION IN FIRST TEN MINUTES OF ACCIDENT o

E0P INTERVENES IN ACCIDENT AS 500N AS POSSIBLE OPERATORACTIOh5INE0PAREBASEDUPONSYMPTONSANDARE o

DIRECTED TO THE NITIGATION OF THE SYMPTON EXHIBITED o

EARLY OPERATOR ACTION ENHANCES ACCIDENT NITIGATION l

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F SJS4T/091791 12 l

o MATCH VALIDATION RCIC TRIP DN RPV LDW PRESSURE 1

o FSAR STATES THAT RCIC IS TRIPPED 0N LOW REACTOR.7 PRESSURE :

o E0P ALLOWS RCIC TO RUN IN LOW PRESSURE CONDITIONS WlEN NEEDED FOR RPV LEVEL CONTROL o

NO CREDIT TAKEN FOR RCIC IN LICENSING ANALYSIS s

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d SJS4T/091791 13 i

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HATCH -VALIDATION._ _:. -:. -.-- - -

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'i CONTAINMENT FLOODING AND VENTING r

o FSAR DOES NOT SPECIFICALLY ADDRESS ACCIDENT CONDITIONS WHICH WOULD REQUIRE CONTAINMENT FLOODING AND VENTING

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o E0P VENTS CONTAINMENT AND REACTOR VESSEL TO PERNIT CONTAINMENT FLOODING AND CORE RESUBMERGENCE j

. _ =

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RESOLVE BY ASSESSING OFFSITE DOSE EFFECTS RESULTING l

P FROM VENTING USING DOSE ASSESSMENT METHODOLOGY BASED I

UPON REALISTIC ASSUMPTIONS o

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o NO FUEL DAMAGE EXISTS FOR DBA LOCA UNDER REALISTIC l

ASSUMPTIONS.

CONSEQUENCES MAINTAINED UNDER PART 100 i-1 i

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l SJ54T/091791 I4 j

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COMPARI5DN WITH LICENSING 1A515 j

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INTENT OF LICENSING BASIS i

i HIGHLY CONSERVATIVE FOR DESIGN AND ANALY115 0F I

P L A N T r.~ r i - =. _+ +. =__..

.1r0 NEVER MEANT TO REFLECT ACTUAL PLANT BEHAVIOR OR PRESCRIBE 0PERATOR ACTIONS In J_." _

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o REQUIRENENT FOR COMPARIS0N- --

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l SER j

LEGAL REQUIRENENT

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o USE OF REALISTIC ANALYSIS / ENGINEERING JUDGMENTS i

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PRIOR NRC AGREEMENT l

4 A PF?OPER WAY TO G0 FOR DIFFERENCE RECONCILIATION.

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SJS4T/091791 15 i

e

CONCLUSIONS i

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RESOLUTION PLAN VALIDATED i

o VERY FEW DIFFERENCES IDENTIFIED j

o MOST DIFFERENCES EASILY RESDLVED i

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o REALISTIC ANALYSIS / ENGINEERING JUDGMENT RESOLVES l

DIFFERENCES l

4 a

o REQUEST NRC AGREEMENT TO PROCEED WITN RESOLUTION PLAN l

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4 16 SJS4T/091791 I

ENCLOSURE 2 f( muc\\

o UNITED STATES

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't - j NUCLEAR REGULATORY COMMISSION WA&MittGTON. D C. 20055 0001

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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:

SUMARY 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. Enclosure 1 lists the attendees, and Enclosure 2 contains the meeting agenda.

Qii.q.4s sion 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 the licensee's evaluation process.

1

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I Mr. W. G. Hairston, III i

Georgia Power Company Edwin I. Hatch Nuclear Plant CC*

Mr. Ernest L. Blake, Jr.

Mr. R. P. Mcdonald j

Shaw, Pittman, Potts and Trowbridge Executive Vice President -

l 2300 N Street, NW.

Nuclear Operations Washington, DC 20037 Georgia Power Company l

P. O. Box 1295 l

Mr. J. T. Beckham Birmingham, Alabama 35201 Vice President - Plant Hatch j

Georgia Power Company Mr. Alan R. Herdt, Chief P. O. Box 1295 Project Branch #3 i

Birmingham, Alabama 35201 U. S. Nuclear Regulatory Commission i

101 Marietta Street, NW, Suite 2900 1

Mr. 5. J. Bethay Atlanta, Georgia 30323 i

Manager Licensing - Hatch Georgia Power Company Mr. Dan H. Smith, Vice President i

P. O. Box 1295 Power Supply Operations j

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 i

Route 1, Scr 439 Paul, Hastings Janofsky & Walker Baxley, Georgia 31513 12th Floor 1050 Connecticut Avenue, NW.

Resident Inspector Washington, DC 20036 U.S. Nuclear Regulatory Comunission l

Route I, Box 725 l

Baxley, Georgia 31513 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, NW. Suite 2900 l

Atlanta, Georgia 30323 Mr. Charles H. Badger Office of Planning and Budget l

Room 610 270 Washington Street, SW.

I i

Atlanta, Georgia 30334 Harold Reheis, Director Department of Natural Resources l

205 Butler Street, SE.

Suite 1252 Atlanta, Georgia 30334 Chairman i

Appling County Comissioners j

County Courthouse Baxley, Georgia 31513 l

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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 agreer.cnt with the licensee's approach to the generic BWROG methodology for the resolution of this issue for Hatch Nuclear Plant, Units 1 and 2.

Kahtan N. Jabbour, Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II t

Office of Nuclear Reactor Regulation

Enclosures:

1.

List of Attendees 2.

Meeting Agenda 3.

GPC Presentation cc w/ enclosures:

See next page N

J 1

4 4

___.a ENCLOSURE 1 May 12. 1993 NRC/GPC Meetino List of Attendees NRC GPC K. Jabbour

0. Vidal R. Frahm J. Heidt W. Long

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ENCLOSURE 2 Acenda for NRC/GPC Meetina 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 OF HATCH E0Ps GPC l

IV.

DISCUSSION OF REVIEW PROCESS GPC l

I 4

V.

DISCUSSION OF INDIVIDUAL CONFLICTS AND RESOLUTIONS GPC l

o HPCI/RCIC suction source 'ransfer o ADS inhibit i

o Standby liquid control initiation criteria 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 o Post accident water level indication VI.

CONCLUSIONS GPC/NRC l

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HATCH 1 AND 2 E0P / LICENSING BASES DIFFERENCES i

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I. Introduction II. Guidance Sumary III. Overview of Hatch E0P IV. Review Process V. Listing of conflicts and resolutions i

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er

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Introduction o

Issue i

SER for Revision 4 to EPGs required licensees I

to assure that the E0Ps did not violate the licensing basis.

1 o

BWROG established task force to resolve issue.

Develop plan to resolve issue.

Develop processes and criteria for utilities

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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 i

realistic methodologies / engineering judgment.

Revising the E0Ps or the licensing basis to resolve the conflict.

o Guidance discussed with NRC and tentatively approved.

'4 Methodology appeared satisfactory.

Audit of Hatch results.

Staff to review ADS inhibit.

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... a 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.

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 1 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.

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Proposed resolution for each conflict was developed.

o GE independently verified these resolutions.

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V.

Differences and Resolutions l

o Ten-total identified.

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GE was contracted to evaluate and resolve conflicts based on SNC proposed resolutions.

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Eight total have been resolved; two remain open.

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HPCI / RCIC suction source.

Designed to auto transfer from CST to torus on high i

torus level.

E0P overrides the transfer.

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Proposed resolution:

Design basis concern is the increased containment

[

loads at increased pool levels.

E0P allows continued suction from CST and utilizes I

~ other limits (i.e. SRV tail pipe level limit) to i

avoid excessive containment loads.

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GE has provided concurrence, issue closed.

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ApS inhibit i

i FSAR only provides for ADS inhibit for ATWS conditions.

t E0P inhibits automatic initiation of ADS under all

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conditions.

Proposed resolution:

Adequate core cooling exists as long as water level is above TAF.

i Initiating ADS at TAF ensures clad temperature

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remains below 2200cF.

l GE has provided concurrence.

The issue is not

closed, however, because NRC actions are not complete.

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SBLC initiation criteria FSAR initiation criteria based on specific rod positions.

It also includes RPV water level i

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.

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GE has provided concurrence, issue closed.

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RCIC low pressure setpoint i

FSAR identifies the low pressure isolation t

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.

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GE has provided concurrence, issue closed.

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5.

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:

BWR Owners Group has contracted with GE and OEI to evaluate the issue for a generic resolution.

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6.

Operator actions within first 10 minutes of an accident.

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.

GE has provided concurrence, issue closed.

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7.

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 is beyond design basis of FSAR cnd Tech Specs.

With water level lowered to 28 inches below TAF, PCT does not exceed 1500cF 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 130cF.

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.

GE has provided concurrence, issue closed.

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1 9.

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 show that for the same

break, E0P Maximum Safe Water Levels or radiation levels will not be exceeded.

Proposed resolution:

E0P places the plant in a safe condition by using nonnal shutdown procedures prior to a Maximum Safe limit being exceeded.

The E0P will initiate an emergency depressurization if Maximum Safe limits are exceeded in more than one area, this is beyond the plant design basis.

i GE has provided concurrence, issue closed.

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N 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 the core shroud.

PRV level instruments may register a level lower than

TAF, in which case the operator is told to flood the primary containment, an evolution not assumed by the FSAR.

Proposed resolution:

Differences justified by assessing realistic off-site dose consequences for the DBA with E0P actions.

The realistic source term for a DBA is miniscl, so the radioactivity release from flooding and venting the 2

containment is within licensing basis limits.

GE has provided concurrence; issue closed.

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