|
---|
Category:Differing Professional Opinion Case File
MONTHYEARML21047A2412021-02-16016 February 2021 DPO-2019-001, Redacted Differing Professional Opinion (DPO) Case File (Public) ML0711502362007-04-16016 April 2007 DPO-2006-002: DPO Followup Actions and Schedule ML0711502382007-04-16016 April 2007 DPO-2006-003: DPO Followup Actions and Schedule ML0712903082007-02-17017 February 2007 DPO Decision-Memo to M. Shannon, Rii, from J. Dyer, NRR, Subject: DPO Panel Response to DPO-2006-002-Final Report ML0711502322007-02-17017 February 2007 DPO-2006-002: DPO Milestones and Timeliness Goals ML0712903022007-02-12012 February 2007 DPO Panel Report Is Final-Memo to J. Dyer, NRR, from J. Grobe, Ades/Nrr, Subject: DPO Panel Response to DPO-2006-002 Final Report ML0711502242007-01-31031 January 2007 E-Mail from R. Pedersen, Dpopm, to EDO Extension Request, Subject: Extension Request for DPO (Atts.- 10/30/2006 e-mail to J. Grobe, Ades/Nrr, from R. Pedersen, Dpopm, Subject: DPOs 2006-002 and -003 Extension Request and Resolution Schedule ML0712902962007-01-29029 January 2007 Email from T. Liu, NRR, to R. Pedersen, Dpopm, Subject: Extension Request to DPO-2006-002 ML0711502232007-01-29029 January 2007 E-Mail from R. Pedersen, Dpopm, to M. Shannon, Rii, Subject: DPO-2006-003 Decision Memo ML0712903192007-01-20020 January 2007 DPO Decision-Memo to M. Shannon, Rii, from J. Dyer, NRR, Subject: DPO Panel Response to DPO-2006-003 ML0711502212007-01-20020 January 2007 DPO-2006-003: DPO Milestones and Timeliness Goals ML0711502202006-12-19019 December 2006 2 Part E-Mail Between R. Pedersen, Dpopm, and M. Shannon, Rii, Subject: Action: DPO-2006-002 Comments ML0711502192006-12-18018 December 2006 Resolution Schedule for DPOs 2006-002 and 2006-003 ML0712902862006-12-0404 December 2006 Email from J. Dyer, NRR, to R. Pedersen, Dpopm, Subject: Office Director Comments on DPO-2006-003 Panel Report ML0712903252006-11-22022 November 2006 Email from M. Shannon, R11, to R. Pedersen, Dpopm, Subject: Action: Review DPO-2006-003 Report ML0711502182006-11-18018 November 2006 DPO-2006-002: DPO Milestones and Timeliness Goals ML0712902832006-11-13013 November 2006 DPO Panel Report-Memo to J. Dyer, NRR, from J. Grobe, Ades/Nrr, Subject: DPO Panel Response to DPO-2006-002 ML0712902552006-11-0808 November 2006 Memo to R. Pedersen, Dpopm, from L. Reyes, EDO, Subject: Approved Extension Request for DPOs 2006-002 and 2006-003 ML0711502152006-11-0707 November 2006 Memo to L. Reyes, EDO, from R. Pedersen, Dpopm, Subject: Extension Request for DPOs 2006-002 and 2006-003, (Encl. 1-DPO-2006-002: DPO Milestones and Timeliness Goals, Encl. 2-DPO-2006-003: DPO Milestones and Timeliness Goals, Encl. 3.. ML0711502142006-10-31031 October 2006 3-Part E-Mail Between R. Pedersen, Dpopm, to M. Shannon, Rii, Subject: Action: Review DPO-2006-003 Report ML0712902512006-10-26026 October 2006 DPO Panel Report-Memo to J. Dyer, NRR, from J. Grobe, Ades/Nrr, Subject: DPO Panel Response to DPO-2006-003 ML0711502012006-09-15015 September 2006 E-Mail from R. Pedersen, Dpopm, to M. Shannon, Rii, Subject: Fyi: Status on DPO-2006-002, DPO-2006-003 ML0712902472006-08-15015 August 2006 DPO Panel 2nd Meeting Agenda - August 15, 2006 DPO 2006-002 and DPO 2006-003 ML0711501992006-08-15015 August 2006 DPO-2006-002 Chronology and Status ML0711501952006-07-20020 July 2006 DPO-2006-002 Chronology and Status ML0712902452006-06-0202 June 2006 DPO Panel Memo-from J. Dyer, NRR, Subject: Ad Hoc Review Panel - DPO Involving Oconee ECCS Sump Screen and Use of Leak Before Break in ECCS ML0711501942006-06-0202 June 2006 June 2006 Monthly Report for DPO-2006-002,-003 ML0711501932006-05-22022 May 2006 DPO Tasking Memo to J. Dyer, NRR, from R. Pedersen, Dpopm, Subject: DPO Involving Oconee Use of Leak Before Break in ECCS ML0711501912006-05-22022 May 2006 DPO Tasking Memo to J. Dyer, NRR, from R. Pedersen, Dpopm, Subject: DPO Involving Oconee ECCS Sump Screens ML0711501902006-05-12012 May 2006 E-Mail from R. Pedersen, Dpopm, to M. Shannon, Rii, Subject: Acceptance of DPOs ML0711501862006-05-12012 May 2006 E-Mail from R. Pedersen, Dpopm, to L. Reyes, EDO, M. Virgilio, Dedmrs, W. Dean, Ao/Edo, Subject: Fyi: New DPO (2006-002) on Oconee ECCS Sump Screens ML0711501882006-05-12012 May 2006 E-Mail from R. Pedersen, Dpopm, to L. Reyes, EDO, M. Virgilio, Dedmrs, W. Dean, Ao/Edo, Subject: Fyi: New DPO (2006-003) on Use of Leak Before Break in ECCS ML0712902442006-05-0303 May 2006 DPO Submittal, DPO-2006-003 from M. Shannon, Rii ML0712902332006-05-0303 May 2006 DPO Submittal, DPO-2006-002 from M. Shannon, Rii ML0605405422005-09-0606 September 2005 DPO Decision ML0524302592005-08-31031 August 2005 DPO-Extension Request ML0607603252005-08-31031 August 2005 Approved Extension Request ML0605405332005-08-17017 August 2005 DPO Report Is Final ML0605800272005-08-10010 August 2005 DPO Extension Request Approval ML0522401712005-08-10010 August 2005 DPO Extension Request ML0606200372005-07-28028 July 2005 Submitter'S Additional Comments on DPO Panel Report ML0605405102005-07-27027 July 2005 Submitter'S Additional Comments on DPO Panel Report ML0605405042005-07-26026 July 2005 Region Ii'S Comments on DPO Panel Report ML0605404982005-07-25025 July 2005 Submitter'S Comments on DPO Report ML0605404352005-07-19019 July 2005 DPO Panel Report ML0605404722005-03-11011 March 2005 DPO Panel Memo ML0505500522005-02-25025 February 2005 DPO Tasking Memo ML0605906512005-02-22022 February 2005 Acceptance of DPO ML0605906532005-02-16016 February 2005 DPO Submittal 2021-02-16
[Table view] Category:Memoranda
MONTHYEARML24122C6932024-05-0101 May 2024 Referral of Petition to Intervene and Request for Hearing Re Subsequent License Renewal Application from Duke Energy Carolinas, LLC for Oconee Units 1, 2 & 3 ML24124A0342024-05-0101 May 2024 Summary of Public Meeting Concerning Annual Assessment of Catawba Nuclear Station Units 1 and 2, McGuire Nuclear Station Units 1 and 2, Oconee Nuclear Station Units 1, 2, and 3, Brunswick Steam Electric Plant Units 1 and 2, Shearon Harris ML24071A1692024-03-15015 March 2024 February 2024 Subsequent License Renewal Public Draft Environmental Impact Statement Meetings-Memo ML24047A2092024-02-22022 February 2024 Calendar Year 2023 Baseline Inspection Completion ML23118A2852023-05-0202 May 2023 Public Meeting Summary - 2022 Annual Assessment Meeting Regarding Catawba Nuclear Station, McGuire Nuclear and Oconee Nuclear Station ML22299A0482023-01-11011 January 2023 Final Environmental Assessment and Finding of No Significant Impact for the Duke Energy’S Updated Decommissioning Funding Plans Submitted in Accordance with 10 CFR 72.30(C) for Oconee Nuclear Station Independent Spent Fuel Storage Installat ML22349A1482022-12-19019 December 2022 Transmittal Letter for Oconee SE for SLRA Review ML22193A2542022-08-0505 August 2022 SLRA - Audit Report ML22111A3142022-05-0202 May 2022 Limited Aging Management Audit Plan Regarding the Subsequent License Renewal Application Review ML22084A6142022-04-0404 April 2022 SLRA - Summary of March 16, 2022 (Closed Public Meeting) ML22024A1392022-03-11011 March 2022 SLRA - Request for Withholding Information ML21347A0102021-12-20020 December 2021 Proposed Alternative to Implement ASME Code Case OMN-26 ML21279A1542021-11-0808 November 2021 August 25, 2021, Oconee Nuclear Station, Units 1, 2, and 3 Subsequent License Renewal Application Public Environmental Scoping Meeting Summary Memo ML21064A3502021-07-26026 July 2021 OEDO-21-00048 - Oconee Nuclear Station, Units 1, 2, and 3 - Response Memorandum ML21195A2692021-07-14014 July 2021 Meeting Summary: Pre-Submittal Meeting for the Oconee Subsequent License Renewal Application (EPID Number: L-2020-RNW-0028) (Docket Numbers: 50 269, 50-270, and 50-287) - Memo ML21055A8672021-04-22022 April 2021 Memo to File: Final Ea/Fonsi of Independent Spent Fuel Storage Facilities Decommissioning Funding Plans Related to Oconee ML21099A0932021-04-0909 April 2021 Public Meeting Summary - 2020 Annual Assessment Meeting Regarding Catawba, McGuire, and Oconee Nuclear Stations ML20357B1332020-12-30030 December 2020 Transmittal Memo - Delivery of Partial Deliverable Associated with the Trace Code Maintenance, Plant Model Maintenance, and Plant Model Development to Support Licensing Actions and Emergent Technical Issues User Need ML20141L4172020-05-20020 May 2020 EOC Public Meeting Summary ML20036E3902020-02-11011 February 2020 Regulatory Audit in Support of Review of License Amendment Request to Revise the Licensing Basis for High Energy Line Breaks Outside of the Containment Building ML19102A3352019-04-12012 April 2019 Public Meeting Summary - Oconee Nuclear Station Docket Nos. 50-269, 50-270, and 50-287 ML19037A0052019-02-0808 February 2019 Regulatory Audit in Support of Review of License Amendment Request No. 2018-02 ML18226A2152019-01-22022 January 2019 Response to Task Interface Agreement 2014-04, Adequacy of the Oconee Nuclear Station Design and Licensing Bases for Degraded Voltage Protection (TAC Nos. MF4622, MF4623, and MF4624; EPID L-2014-LRA-0003) ML18082A0582018-03-23023 March 2018 Summary of Meeting with Oconee Nuclear Station to Discuss Annual Assessment of Oconee for the Period of January 01, 2017 - December 31, 2017 ML18032A4612018-03-0505 March 2018 Regulatory Audit in Support of Review of License Amendment Request No. 2017-03 ML18004A0122018-01-0404 January 2018 Regulatory Audit in Support of Review of Proposed Alternative (CAC Nos. MF7365, MF7366 and MF7367; EPID No. L-2016-LLR-001) ML17264A0312017-09-29029 September 2017 Draft Response to Task Interface Agreement 2014-05 to Licensee Oconee Design Analysis for Single Failure/Integration of Class 1E Direct Current Control Cabling in Raceways with High Energy Power Cabling ML17202U7312017-07-25025 July 2017 Regulatory Audit in Support of License Amendment Request No. 2015-03 ML17103A0292017-04-13013 April 2017 Summary of Meeting to Provide Opportunities to Discuss Annual Assessment of Oconee Nuclear Station Units 1, 2 and 3 ML16088A2042016-03-28028 March 2016 Memo T Bowers from s Ruffin, Technical Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations W/ Encl 2 (Template) ML16088A2052016-03-28028 March 2016 Enclosure 1 - (72.30 DFP Reviews to Be Completed 2015) - Memo T Bowers from s Ruffin, Technial Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations ML16061A5652016-03-0909 March 2016 Request for Additional Information for Relief Request 14-ON-001, Letdown Cooler Nozzle Welds ML16056A5832016-02-26026 February 2016 and 3, Draft Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Based on NEI 99-01 Rev.6 ML16021A3452016-01-29029 January 2016 Draft Request for Additional Information License Amendment to Add High Flux Trip for 3 Reactor Coolant Pump Operation ML15364A3802016-01-0808 January 2016 Draft Request for Additional Information Relief Request ON-GRR-01 ML15363A2962015-12-29029 December 2015 Special Inspection Charter to Evaluate the Power Cable Failures/Degradations on the Oconee Units 1 and 3 Startup Transformers ML15345A3982015-12-15015 December 2015 Draft Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Based on NEI 99-01 Rev. 6 ML15265A1272015-09-17017 September 2015 Memoranda to C. Bladey Notice of Availability of Exemption for Duke Energy Carolinas, LLC, Oconee Nuclear Station Independent Spent Fuel Storage Installation ML15231A1922015-08-19019 August 2015 NRC June 9 2009 Memo Revision ML15233A4952015-08-14014 August 2015 Memo to C Bladey, Notice of Environmental Assessment and Finding of No Significant Impact - Duke Ene4rgy Carolinas LLC, Oconee Nuclear Station ISFSI - Admin EA Memo ML15181A4332015-07-0707 July 2015 Closure of Licensee Responses to External Flooding Letters ML15099A5612015-05-11011 May 2015 Safety Evaluation for Duke Submittal on Electronic Records (Nirma) ML15089A1642015-04-27027 April 2015 Summary of February 25, 2015, Partially Closed Meeting with Industry Stakeholders Regarding the Babcock and Wilcox Loss of Coolant Accident Evaluation Model Analysis ML15113A6262015-04-23023 April 2015 April 14, 2015 Summary of Public Meeting on Oconee Nuclear Station, Units 1, 2 and 3 to Discuss the Annual Assessment ML14356A0052014-12-31031 December 2014 Summary of December 3, 2014, Category 1 Public Meeting with Duke Energy Carolinas, LLC to Discuss NTTF Recommendation 2.1, Flooding Response for Oconee Nuclear Station, Units 1, 2, and 3 ML14311A8622014-11-0707 November 2014 Request for Technical Assistance Regarding the Adequacy of the Oconee Station Design and Licensing Bases for the Degraded Voltage Relay Protection Design (TIA 2014-04) (Final) ML14147A3652014-05-27027 May 2014 Annual Assessment Public Meeting Summary Memo ML14055A4742014-02-0404 February 2014 Draft Memorandum from G. Cunningham, NRR to E. Leeds, NRR on Oconee Flood Protection and the Jocassee Dam Hazard Basis for Continued Operation ML14058A0162014-02-0404 February 2014 Draft Memo from M. Cunningham, NRR Et Al to E. Leeds, NRR on Oconee Flood Protection and the Jocassee Dam Hazard Basis for NRC Allowing Continued Operation ML14058A0172014-02-0404 February 2014 Draft Memo from M. Cunningham, NRR Et Al to E. Leeds, NRR on Oconee Flood Protection and the Jocassee Dam Hazard Basis for NRC Allowing Continued Operation 2024-05-01
[Table view] |
Text
September 6. 2005 MEMORANDUM TO: Mel Shannon, Senior Resident Inspector (Oconee)
Projects Branch 1 Division of Reactor Projects FROM: William D. Travers, Regional Administrator/RA/
SUBJECT:
DIFFERING PROFESSIONAL OPINION DECISION REGARDING OCONEE PIPE WHIP RESTRAINT (DPO-2005-003)
The purpose of this memorandum is to provide the management decision for the Differing Professional Opinion (DPO) regarding the Oconee pipe whip restraint that you submitted on February 16, 2005. In accordance with Management Directive 10.159, The Differing Professional Opinions Program, I appointed an Ad Hoc Review Panel on March 11, 2005, to conduct an independent review of your concerns. The panels review focused on three primary concerns:
- 1. The licensees fatigue analysis of the improperly adjusted pipe whip restraint contained errors and the licensees evaluation failed to consider the increased probability of pipe failure resulting from the stresses applied by the improperly adjusted pipe whip restraint.
- 2. The staffs review of the licensees calculation was inadequate.
- 3. The staffs application of the Reactor Oversight Process in regards to the improperly adjusted pipe whip restraint was inappropriate.
The panel provided the results of their review on July 19, 2005, and reached the following overall conclusions:
- The increased stresses imposed by the improperly adjusted pipe restraints did not result in a strain which approached the ultimate material strain of the pipe.
Hence, pipe failure as a result of a one-time load application was unlikely.
- The issue was appropriately dispositioned in Oconee Inspection Report 2004-005 given the assumption in the inspection report that pipe failure would not occur.
- The Regions review of the issue was appropriate.
In reaching my decision, I reviewed the panels report, discussed the report with the panel chair, and reviewed the additional comments you provided on the panels report on July 25, July 27, July 28, and August 19, 2005. Based on this review, I agree with the conclusions of the panel.
M. Shannon 2 The panel provided three recommendations. My decisions regarding the recommendations, and the rationale for the decisions, are provided below.
Recommendation 1: NRR, explore revising the ROP to allow for the processing of performance deficiencies involving issues/initiating events that are not amenable to treatment using existing statistical techniques.
Decision: Agree with the recommendation. Region II will prepare and forward a memorandum to the Director of the Office of Nuclear Reactor Regulation (NRR) recommending that a review be conducted to develop possible alternate approaches to determining the significance of findings for those issues that are not amenable to treatment using the current Significance Determination Process tools. The alternate approaches should consider the complexity of the issue, deterministic and statistical uncertainties, and the resources needed to determine the significance of the issue before starting any approach.
Rationale: The panel found that the current risk analysis tools that are used in determining the significance of inspection findings may not be adequate, or appropriate, for all types of findings. In this specific case, the panel concluded that adequate techniques for correlating the increase in pipe stress to an increased probability of pipe failure were not available. A significant amount of valuable staff resources (inspectors and risk analysts) were expended in evaluating the significance of this finding. The purpose for reaching a decision regarding the significance of a finding is to determine the appropriate regulatory response to the issue, including supplemental inspection and pertinent regulatory actions ranging from management meetings up to and including orders for plant shutdown. Region II has had similar experiences with other findings where the resources could have been more effectively used, and in a more timely manner, if there was an alternate approach to determining the significance of some findings. In some cases, the resources expended in determining the significance of a finding far exceeded the resources eventually expended in responding to the issue. The review of this DPO, along with Region IIs experience during the first four years of the Reactor Oversight Process, have highlighted the need for a more rigorous decision-making process prior to the expenditure of resources for a complex risk analysis where large uncertainties are expected, and alternate approaches for reaching decisions on the appropriate regulatory response.
Recommendation 2: Include the improperly adjusted pipe restraints in the next PI&R sample inspection performed by Region II. Specifically examine the following attributes during this inspection:
- licensee corrective actions to ensure that the clearances/gaps in the restraints are maintained
- the need for the licensee to conduct routine pipe wall thickness measurements in the vicinity of the pipe restraints. If no requirements exist in this area, engage the licensee on the desirability of conducting these measurements.
- whether calculation errors in Revision 1 of the calculation were appropriately processed in the licensees corrective action program.
- extent of condition reviews performed by the licensee regarding other similar restraints.
M. Shannon 3 Decision: Agree, in part, with the recommendation. Region II will include the improperly adjusted pipe restraints as a specific sample in a Problem Identification and Resolution Inspection. The inspection will examine the licensees corrective actions to ensure that the clearances/gaps in the restraints are maintained, whether calculation errors were appropriately processed in the corrective action program, and that extent of condition reviews were performed by the licensee regarding other similar restraints.
Regarding the recommendation to examine the need for the licensee to conduct routine pipe wall thickness measurements in the vicinity of the pipe restraints, the staff should determine whether requirements exist in this area as part of preparing for the inspection.
If no regulatory requirements exist in this area, and the licensee has elected not to perform the measurements then the need for a backfit will need to be evaluated. The licensee should not be engaged on the desirability of conducting these measurements until the appropriate regulatory process is determined.
Rationale: The issues involved in this finding warrant followup using the flexibility provided in Inspection Procedure 71152, Identification and Resolution of Problems. The recommendation regarding engaging the licensee on the desirability of conducting routine pipe wall thickness measurements appears to approach imposing a backfit on the licensee. The inspection staff should determine if there are any requirements to conduct the measurements before conducting the inspection. If there are no requirements for the measurements, then the staff will need to conduct a backfit analysis to justify imposing this requirement on the licensee.
Recommendation 3: Region II, develop a feedback form for MC 0612 to specifically require that inspection report writeups document the details of phone calls between the inspectors and NRR used to resolve inspection issues of a technical nature. Additionally, when such calls are referenced in the inspection report, change MC 0612 to require report concurrence by key NRR participants and the responsible NRR BC.
Decision: Agree with the recommendation. Region II will develop a feedback form that will recommend that MC 0612 be revised to require that inspection reports document conversations (telephone calls, emails, meetings, etc.) between the inspection staff and technical staff members, where those conversations provide a basis for a regulatory decision documented in the inspection report. In addition, the responsible Branch Chief for the technical staff should concur on the inspection report when these discussions are documented.
Rationale: The panel concluded that telephone calls were conducted with NRR personnel as part of the review of the unresolved item. However, details associated with these calls were not documented in the inspection report or on the docket. This could result in situations where the basis for a regulatory decision is unclear and not retrievable. By revising MC 0612 to require that inspection reports document the details of discussions between the inspectors and technical experts, and that the appropriate Branch Chief concur in the report, when those discussions provide a basis for the regulatory decision, the traceability for the NRCs decision is insured.
ML060540542___
OFFICE RII:ORA SIGNATURE LRP NAME LPlisco DATE 09/06/05 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO