ML071150215
| ML071150215 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/07/2006 |
| From: | Pedersen R NRC/OE |
| To: | Reyes L NRC/EDO |
| References | |
| DPO-2006-002, DPO-2006-003, FOIA/PA-2007-0162 | |
| Download: ML071150215 (7) | |
Text
November 7, 2006 MEMORANDUM TO: Luis A. Reyes Executive Director for Operations FROM:
Ren6e Pedersen, Differing Professional Opinions
/RA/
Program Manager Office of Enforcement
SUBJECT:
EXTENSION REQUEST FOR DIFFERING PROFESSIONAL OPINIONS INVOLVING OCONEE ECCS SUMP SCREENS (DPO-2006-002) AND OCONEE USE OF LEAK BEFORE BREAK IN ECCS (DPO-2006-003)
The purpose of this memorandum is to inform and advise you about an extension request that I received from Jack Grobe, the DPO Panel Chair for the subject Differing Professional Opinions (DPOs). In a memorandum dated August 18, 2006, you approved new timeliness goals that were recommended in the 2005 DPO Program Review (ML061980069). The EDO-approved timeliness goal to disposition a DPO is 130 - 190 calendar days. You also directed that the staff continue to submit extension requests aligned with the new timeliness goals to the Executive Director for Operations (EDO) in accordance with Management Directive (MD) 10.159, "The NRC Differing Professional Opinions Program." The current Milestones and Timeliness Goals for these DPOs are included as Enclosure 1 and Enclosure 2.
The DPO Panel seeks an extension to disposition DPO-2006-002 to December 18, 2006, and DPO-2006-003 to December 4, 2006. This extension request has been reviewed and approved by Jim Dyer, NRR, Office Director (OD). A detailed explanation of scheduling issues is included in the extension request (Enclosure 3). In summary, the schedule has been impacted by several factors: (1) the initiation of work by the DPO Panel was delayed due to competing priorities and travel schedules, (2) the review was more complex due to reviewing two DPOs, (3) the age of the issues, and (4) the need for legal assistance.
I have reviewed the extension requests and recommend that you approve the extension requests for the disposition of DPO-2006-002 to December 18, 2006, and DPO-2006-003 to December 4, 2006.
If you approve the extension requests, I will revise the Milestones and Timeliness Goals and provide them to Jim Dyer, NRR, OD, the DPO Panel, and the submitter.
Please feel free to contact me if you have any questions or require any additional information (415-2742, email rmpcDnrc.gov).
Enclosures:
- 1.
Milestones and Timeliness Goals for DPO-2006-002: Oconee ECCS Sump Screens
- 2.
Milestones and Timeliness Goals for DPO-2006-003: Oconee Use of Leak Before Break in ECCS 73-12
L. Reyes
- 3.
Email from J. Grobe DPO Panel Chair: Extension Requests for DPO-2006-002 and DPO-2006-003 dated 10/30/2006 cc: M. Virgilio, DEDMRS DISTRIBUTION:
M. Johnson, AO W. Kane, DEDR J. Dyer, NRR J. Grobe, NRR (DPO Panel Chair)
DPO Panel members DPO Submitter DPO-2006-002 file DPO-2006-003 file DPO Day File ADAMS-Non public, DPO Staff=Owner
L. Reyes
- 3.
Email from J. Grobe DPO Panel Chair: Extension Requests for DPO-2006-002 and DPO-2006-003 dated 10/30/2006 cc: M. Virgilio, DEDMRS DISTRIBUTION:
M. Johnson, AO W. Kane, DEDR J. Dyer, NRR J. Grobe, NRR (DPO Panel Chair)
DPO Panel members DPO Submitter DPO-2006-002 file DPO-2006-003 file DPO Day File ADAMS-Non public, DPO Staff=Owner FILE NAME: G:\\DPO Program\\DPO-2006-002\\DPO Extension Request to EDO.wpd ADAMS ACN: ML063100334 UI-I IUI UIJUFM/(JL-UU/UL-ju__
NAME R. Pedersen J. Luehman I C. Carpenter DATE 11/06/06 11/07/06 11/07/06 OFFICIAL RECORD COPY DPO-2006-002: Oconee ECCS Sump Screens
Subject:
This DPO raises concerns about new ECCS sump screens at the Oconee facility. The submitter contends that the new sump screens can be impacted by jet impingement from an RCS cold leg break (LOCA) and that the licensee should be required to perform an analysis (per GDC-4) prior to installation.
Assigned to:
Jim Dyer, NRR OD DPO Panel: Jack Grobe, NRR, Panel Chair/Mark Caruso, NRR/ Aladar Csontos, RES/
Joe Lenahan, RII DPO Milestones and Timeliness Goals DPO Milestone Timeliness Actual Goals Date Individual submits DPO (NRC Form 680)
None 05/12/2006 DPOPM screens and accepts DPO 8 CDs 05/12/2006 DPOPM assigns DPO to OD or RA 5 CDs 05/22/2006 OD or RA establishes DPO Panel1 14 CDs 06/02/2006 DPO Panel meets with submitter 2 8 CDs 07/20/2006 DPO Panel collects, reviews, and evaluates information3 30 - 90 CDs 08/15/2006 (date when DPO Panel completes review)
DPO Panel writes report 30 CDs OD or RA comments on DPO Panel report 10 CDs submitter comments on DPO Panel report DPO Panel evaluates comments and either revises 7 CDs report or declares original report final OD or RA issues DPO Decision 21 CDs TOTAL CDs (from acceptance of DPO) 130 - 190 CDs Initial Goal = 08/19/2006 - 11/18/2006
'Given the scope of the concerns, the NRR, OD established one DPO Panel to address DPO-2006-002 and DPO-2006-003.
2Unanticipated scheduling issues delayed the meeting with the submitter.
3DPO Panel requested OGC interpretation of GDC 4.
I i
DPO-2006-003: Oconee Use of Leak Before Break in ECCS
Subject:
This DPO raises concerns about the installation of an ECCS LPI cross tie header at the Oconee facility. The submitter contends that the licensee should not have been allowed to use Leak Before Break technology for ECCS.
Assigned to:
Jim Dyer, NRR OD DPO Panel: Jack Grobe, NRR, Panel Chair/Mark Caruso, NRR/ Aladar Csontos, RES/
Joe Lenahan, RII DPO Milestones and Timeliness Goals DPO Milestone Timeliness Actual Goals Date Individual submits DPO (NRC Form 680)
None 05/12/2006 DPOPM screens and accepts DPO 8 CDs 05/12/2006 DPOPM assigns DPO to OD or RA 5 CDs 05/22/2006 OD or RA establishes DPO Panel4 14 CDs 06/02/2006 DPO Panel meets with submitter5 8 CDs 07/20/2006 DPO Panel collects, reviews, and evaluates information6 30 - 90 CDs 08/15/2006 (date when DPO Panel completes review)
DPO Panel writes report 30 CDs 10/26/2006 OD or RA comments on DPO Panel report 10 CDs submitter comments on DPO Panel report DPO Panel evaluates comments and either revises 7 CDs report or declares original report final OD or RA issues DPO Decision 21 CDs TOTAL CDs (from acceptance of DPO) 130 - 190 CDs Initial Goal = 08/18/2006 - 11/17/2006 4Given the scope of the concerns, the NRR, OD established one DPO Panel to address DPO-2006-002 and DPO-2006-003.
5Unanticipated scheduling issues delayed the meeting with the submitter.
6DPO Panel requested OGC interpretation of GDC 4..
From:
John Grobe To: Renee Pedersen Date: 10/30/2006 11:55:17 AM
Subject:
DPOs 2006-002 and -003 Extension Request
- Renee, See the enclosed schedule/justification for extended closure of the subject DPOs. Jim Dyer supports this schedule extension. If there is anything that I can do to facilitate your generation of the memo to the OEDO, please let me know.
Note that one of the due dates for -002 (7 days for the Panel to resolve comments on the report) spans Thanksgiving week. I will be very comfortable with the report before it goes forward, so I do not anticipate significant comments, but in the event that there are, this may be a challenge.
Thanks.
Jack CC:
DPO Panel; Jim Dyer; Michael Weber
Cr RESOLUTION SCHEDULE FOR DPOs 2006-002 AND 2006-003 Below is listed the projected schedules for resolution of the two subject DPOs.
The delays have been related to several factors:
- The initiation of Panel work and scheduling the first Panel meeting was delayed due to several other competing priorities and travel schedules of various Panel members (approximately one and one-half month delay).
" The review was more complex than normal DPO Panel activities due to the assignment of two DPOs to one Panel. This assignment was appropriate due to the similarities between the DPOs, but increased the Panel workload handling the two issues simultaneously.
" The issues involved in the DPOs had their root in actions taken by the NRC approximately 20 years ago with multiple revisions of GDC-4. Due to age of the background materials, reconstruction of the history was complicated and time consuming.
" Because the matter involved in resolving the DPOs concerned an interpretation of the revisions to GDC-4, the Panel determined that it desired a review of its conclusions by the Office of General Counsel (approximately two week delay).
DPO Milestone Panel issues report DPO-2006-002 11/09/2006 DPO-2006-003 10/26/2006 (complete)
OD/Submitter comments on Panel Report (10 calendar days)
Panel evaluates comments and issues final report (7 calendar days)
OD issues DPO decision (21 calendar days) 11/19/2006 11/27/2006 12/18/2006 11/06/2006 11/13/2006 12/04/2006 Total 220 calendar days (target 130-190 calendar days) 206 calendar days