ML20042D175

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Provides Clarification of SER Cover Ltr Statement That ... Licensee Who Wishes to Use Rev 4 of Emergency Procedure Guidelines (EPG) Should Assure That EPGs Will Not Impact Licensing Basis, Per 890817 Request
ML20042D175
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 10/05/1989
From: Thadani A
Office of Nuclear Reactor Regulation
To: Floyd S
BWR OWNERS GROUP
Shared Package
ML17056C371 List: ... further results
References
CON-IIT07-496-91, CON-IIT7-496-91 NUREG-1455, NUDOCS 8911010044
Download: ML20042D175 (2)


Text

p '1,4 9 6 9 i OCT " 51989 Stephen D. Floyd, Chairman BWR Owners' Grow c/o Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602

Dear Mr. Floyd:

BWR EMERGENCY PROCEDURE GUIDELINES, REY. 4, NED0-31331, MARCH 198

SUBJECT:

Letter (BWROG-8964) from S.D. Floyd (BWROG) to A.C. Thadani (NRC),

References:

dated August 17, 1989.

In the referenced letter, the Owners' Group requested a clarification to the SER cover letter statement that "... licensee who wishes to use the Re of the Emergency Procedure Guidelines (EPG) should assure that the EPGs will not impact its licensing basis." This letter provides the requested clarification.

The staff recognizes that the EPG addresses a wide range of postulated events includinganticipatedtransients,designbasisaccident(DBAs),andevents beyond the plant's licensing basis as a result of multiple equipm postulated events, the EPG uses a symptom-based approach and specifies use or operator errors.

nonsafety grade equipment, not used in performing the plant safety analyses, This approach is consistent with the requirements and safety grade equipment.

of NUREG-0737 Item I.C.I.

However, for those postulated anticipated transients and DBAs analyzed in the FSAR, ityas_ recognized _that.certain plant specific operator actions may.have been assumed. to assure _conformanceyitLthe applicable regu.latory

_te.qu.irements..._Given the generic approach utilized to Each licensee will use the EPG to develop a plant specific set of Following the development of these the EPG.

Emergency Operating Procedures (E0Ps).E0Ps, the staff exp.ects thoseplMtsie^c~ific'~operatoractionsspecified.intheFSARorprovide

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operator' action's which still ensure that the regulatory requirements-are Litiified fof Th'ose events specifically analyzed in the FSAR.

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, Stephen D. Floyd For those events which are beyond the specific conditions analyzed as part of the FSAR, it is recognized that the E0Ps may result in actions not previously These actions were generically examined by the staff specified in the FSAR.

as part of the EPG review and were found appropriate for the extremeThus, furth situations which require their use.

is not required.

If you require any questions regarding the implementation of the EPG, please

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contact Robert Jones of my staff at 301-492-3232.

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Sincerely, 5

Ashok C. Thadani, Director Division of Systems Technology Office of Nuclear Reactor Regulation cc:

F. Miraglia M. Rubin C. E. McCracken J. Kudrick D. Florek (Region I)

M. W. Hodges (Region I) j SRXB Meirbers 1

Contact:

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