ML102100007
| ML102100007 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/28/2010 |
| From: | Mark Franke NRC/RGN-II/DRS/EB3 |
| To: | |
| References | |
| IR-01-003 | |
| Download: ML102100007 (8) | |
Text
NRC FORM NRC FORM 757 757 u.s. NUCLEAR REGULATORY U.S. NUCLEAR REGULATORY COMMISSION COMMISSION NRC MD NRC MD 10.158 10158 (3-2009)
(3*2009)
NON-CONCURRENCE PROCESS SECTION A SECTION A - TO
- TO BEBE COMPLETED COMPLETED BY BY NON-CONCURRING INDIVIDUAL NON-CONCURRING INDIVIDUAL TITLE OF TITLE OF DOCUMENT DOCUMENT ADAMS ADAMS ACCESSION NO. NO.
Inspection Report St. Lucie Inspection 05000389/2010003 Reøort 05000389/2010003 DOCUMENT SPONSOR DOCUMENT SPONSOR SPONSOR SPONSOR PHONEPHONE NO.
NO.
Mark Franke Mark Franke 404-997-4436 404-997-4436 NAME OF NAME OF NON-CONCURRING INDIVIDUAL NON-CONCURRING INDIVIDUAL PHONE PHONE NO. NO.
Walt Rogers 404-997-4619 D DOCUMENT AUTHOR DOCUMENT AUTHOR D DOCUMENT CONTRIBUTOR DOCUMENT D DOCUMENT REVIEWER DOCUMENT REVIEWER ~ ON ON CONCURRENCE TITLE TITLE ORGANIZATION Senior Reactor Analyst DRS/EB2 IDRSlEB2 REASONS FOR NON-CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance. The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivtiesactiivties..
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NRC FORM 757 NRC NUCLEAR REGULATORY COMMISSION U.S. NUCLEAR 10.158 NRC MD 10.158 (3-2009)
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT IADAMS ACCESSION NO.
05000389/2010003 St. Lucie Inspection Report 0500038912010003 SECTION B - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S
- INDMDUALS SUPERViSOR SUPERVISOR (THIS SECTION SHOULD ONLY BE BE COMPLETED IF DIFFERENT THAN DOCUMENT SPONSOR.)
IF SUPERVISOR IS DIFFERENT NAME Rebecca L. Nease TITLE PHONE NO.
Cbief, Engineering Brancb
- Chief, ORGANIZATION ORGANIZATION Branch 2 I 404-997-4530 Division of Reactor Safety. Safety, Region IID COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER D II HAVE HAVE NO COMMENTS
!ill II HAVE THE FOLLOWING COMMENTS I have bave reviewed the tbe attacbed attached documentation, and it appears that tbat all parties have faitb, to consider all views bave acted in good faith, witb repsect to the with tbe subject of tbis this non-concurrence. At issue is whether wbetber is is appropriate to use the shutdown operations tbe sbutdown significnce determination process (SDP) or the tbe at-power SDP for tbethe described performance deficiency. While a conclusion reacbed tbat was reached that sbutdown shutdown risk was not to be considered, it appears that this was not a consensus view among the tbat tbis tbe staff in NRR and Region II. D. In addition, it appears tbat have supported eitber tbe guidance could bave that the either view, depending on which wbicb part of tbe the guidance was referenced. Tbis This ambiguity does not speak well for our principals of good regulation, especially tbe the principal of clarity.
Having reviewed tbe the documents attacbed attached berein, each view, eitber herein, and read eacb either metbodology (shutdown risk or at-power risk) methodology (sbutdown appears to meet at least some parts oftbe shutdown risk to conclude a bigber of the guidance. However, in using sbutdown higher risk level, we would havebave hadbad tbe the opportunity (witbin (within tbe the guidance) to send a strong message to tbe the licensee tbat that repeatedly entering a risk-signficant plant configuration to fIX fix tbe the same or similar degraded condition is not in tbe the interest of safety. I believe tbe the confusing guidance bears revision to provide clarity to tbe the process and to permit sucb such latitide in egregious cases, sucb this such as tbis one.
D CONTINUED CONTINUED IN SECTION D D Ii ~
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, NRC FORM NRC FORM 757 NRC MD10.158 NRC MD 10158 (3-2009) 757 U.S.
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NON-CONCURRENCE PROCESS NON~ONCURRENCEPROCESS TITLE OF TITLE OF DOCUMENT DOCUMENT IADAMS ADAMS ACCESSION ACCESSION NO. NO.
St Lucie 8t Lucie Inspection Inspection Report Report 05000389/2010003 05000389/2010003
~I-------------------
SECTION CC - TO SECTION - BE COMPLETED TO BE COMPLETED BY DOCUMENT SPONSOR BY DOCUMENT SPONSOR NAME NAME Mark Franke Mark Franke TITLE TITLE PHONE PHONE NO.NO.
Branch Chief Branch Chief 404-997-4436 ORGANIZATION I 404-997-4436 ORGANIZATION DRS/EB3 DRSlEB3
-ACTIONS - -TAKEN ACTIONS TAKEN
- -TO -ADDRESS TO ADDRESS NON-CONCURRENCE (This NON-CONCURRENCE (This section section should should bebe revised revised,, as necessary, to as necessary, to reflect reflect the the final final outcome outcome ofof the the non-concurrence process, non-concurrence process, including including aa complete complete discussion discussion ofof how individual concerns how individual concerns were were addressed.)
addressed.)
The issue at The at the heart of this this non-concurrence non-concurrence is whether it it is appropriate to assess shutdown shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed failed seal line finding.
II believe believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and and NRR DIRS and DRA.
On March On March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix G, C, Shutdown Operations Significance Determination Determination Process, should not be used to evaluate this finding and stated that NRRIDRA did not believe this performance deficiency affected operations during shutdown conditions. Lois James NRRlDRA referenced IMC 0609 ,, the RASP Handbook, and a review of past findings as the basis for this decision. Her email of 3/3/20 10 describes this argument and it is attached.
3/3/2010 Additional Additional meetings meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, perpectives.
came to to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance Performance Assessment Assessment Branch, expressed expressed concern over the whether whether it was programmati programmatically cally appropriate and consistent to use use Appendix Appendix G G for this finding considering considering that the finding occurred At-power.
On April April 30, 30, 2010, 2010, after considering all all of the perspectives, of the perspectives, John Lubinski Lubinski (acting DRS director) determined that it was consistent consistent with our our process and practice practice to process to to treat thisthis as as an At-Power finding. In other words, words, we would not not view this this asas aa finding finding warranting an Appendix C G risk assessment. It would screen out It would out per per IMC 0609 0609 Phase Phase 11 screening. To To perform perform maintenance maintenance to to correct correct the the leak, leak, the the licensee licensee shutdown shutdown and entered entered reduced reduced inventory inventory operation.
operation. We We did did not not identify identify performance performance deficiencies deficiencies associated associated withwith the the licensees licensee's shutdown shutdown operations operations or or maintenance maintenance risk managment.managment.
(Reference (Reference Lubinski Lubinski email email 4/30/10, 4/30110, attached).
attached). Rani Rani Franovich, Franovich,Chief Chief of of Performance Performance Assessment, agreed agreed withwith this decision decision via email via email on on 6/4/2016/4/2010. 0.
II have have reviewed reviewed this this non-concurre non-concurrence nce documentatio documentation n in in detail.
detail. It illustrates the It illustrates the numerous numerous important important arguments arguments and and counter-argu counter-arguments ments that that the staff discussed the staff discussed and and highlights highlights several several areasareas for for potential potential SDPSDP guidance guidance clarification.
clarification. Because Because II believe believe that that these these arguments arguments were were thoughtfully thoughtfully considered considered in in the the April April 3030 decision, decision, II do do not not propose propose reversing reversing thatthat decision.
decision.
The performance The performance deficiency deficiency was was not not viewed viewed to to extend extend intointo the the licensees licensee's decisions decisions to to shutdown shutdown and and repair.
repair. To To address address staff staff division division and and concerns concerns overover this, this, DIRS DIRS initiated initiated an an effort effort toto examine examine whether whether changes changes werewere needed needed in in NRC NRC procedures procedures to to ensure clarity, ensure clarity, reliability, and efficiency reliability, and efficiency going going forward.
forward. DIRS DIRS initiated initiated an an ROP ROP feedback feedback formform to to track track thisthis effort.
effort.
(Reference (Reference Franovich Franovich email 6/4/10) II believe, email 6/4/10) believe, on on balance, balance, that that the the decisions decisions to to treat treat this this finding finding as as an an At-Power At-Power finding finding and and to to conduct conduct aa review review ofofour our guidance guidance are are inin the the interests interests of of ROP ROP reliability reliability andand clarity, clarity, which which areare inin the the the the public public interest.
interest.
This path This path also also provides provides forfor additional additional stakeholder stakeholder participation participation and and communicati communication should SDP on should SDP guidance guidance revisions revisions occur.
occur.
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Lo -LQA Franke, Mark Franke, Mark From:
From: Nease, Rebecca Nease, Rebecca Sent:
Sent: Friday, March Friday, March 05, 05, 20102:34 2010 2:34 PM PM To: Franke, Mark; Vargas, Franke, Vargas, Alexandra
Subject:
Subject:
FW: SDP Phase FW: Analysis Of St.
Phase 3 Analysis Lucie Rep St. Lucie RCP Seal Leak-Off Leak-Off Line Line Leak Leak NRRs basis NRR's basis for notnot using using App G. G.
From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM Sent:
To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie
Subject:
SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line Line Leak
- Rebecca, The Probabilistic Risk Assessment Operational Support Sranch Branch (APOS)
(APOB) was requested by Engineering Branch 2 in the Division of Reactor Safety in Region II to perform a Phase 3 Significance Determination Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) required unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance deficiency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld. J-weld.
APOB APOS staff forwarded the Phase 3 SDP to Region II staff on February 24, 2010.
During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place.
place. Clearly, the performance deficiency caused aa TS require unit shutdown, however, the performance deficiency, deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRR/DRA NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Significance Determination Process, should be used to evaluate this finding.
In addition, NRRlDRA NRR/DRA believes that this performance performance deficiency does not not affect the operations during shutdown conditions conditions and that available guidance provides that IMC 0609, Appendix G, is applicable to finding that affect the operations during shutdown conditions. conditions.
- IMC IMC 0309 Appendix G, G, Shutdown Operations Significance Determination Determination Process (IMC (IMC 0609, 0609, App App G), states that:
G), states that:
oo For For deficiencies deficiencies occurring occurring aboveabove the the RHR RHR entry entry conditions, thethe full full power power SDP SDP tools tools should should be be used.
used ....[section
. [section 2.1]
2.1]
oo An initiating An initiating event event at at shutdown shutdown is is defined defined as as an event that an event that causes causes aa loss loss or or interruption interruption of of the the decay decay heat heat removal removal function. [section [section 4.0]4.0]
- IMC 0609 Attachment IMC 0609 Attachment 44 provides provides guidance guidance that that performance performance deficiencies deficiencies during during shutdown shutdown modes modes to be evaluated using Appendix to be evaluated using Appendix G: G:
oo IFIF the the finding finding affects:
affects: the the safety safety of of aa reactor reactor during during refueling refueling outages, outages, forced forced outages, outages, and and maintenance maintenance outages outages starting, when the starting, when the licensee licensee has has met met the the entry entry conditions conditions for for RHR RHR and and RHR RHR cooling cooling has has been been initiated, initiated, THENTHEN STOP.
STOP. Go Go to to IMC IMC 0609, 0609, Appendix Appendix G. G.
- The The RASP RASP Handbook Handbook provides provides aa specific specific exception exception when when repair repair time time should should not not be be included included in in the the exposure exposure time time toto deal with this deal with this type type ofof finding:
finding:
oo IfIf the the plant plant isis shutdown shutdown and and the the deficiency deficiency only only affects affects an an at-power at-power condition, condition, then then repair repair time time should should notnot bebe included included 11
Further, NRRlDRA Further. NRR/DRA performed performed aa quick quick search search of findings on of findings on the Dynamic Webs the Dynamic Webs Page Page toto identify identify findings findings that that were found were found at-power at-power andand included included risk risk insights insights from from IMC IMC 0609 0609 Appendix Appendix G,G, Shutdown Operations Significance Shutdown Operations Significance Determination Process.
Determination Process. No No findings findings were were identified identified that that applied applied IMC IMC 0609 0609 Appendix Appendix G G toto an an at-power at-power finding.
finding.
We could only locate items We could only locate items that that used used IMC IMC 0609 0609 Appendix Appendix G when the C when the items items were were identified identified during during shutdown.
shutdown.
In conclusion, In conclusion, while while the PRA analysis the PRA analysis completed completed thatthat was was forwarded forwarded toto your your staff staff on on February February 24, 24, 2010, 2010, is is technically adequate technically adequate in in calculating calculating the the risk risk associated associated with with reduced reduced inventory, inventory, NRRlDRA NRR/DRA does does not believe that not believe that IMC 0609 IMC 0609 Appendix G, Shutdown Operations G, Shutdown Operations Significance Significance Determination Determination Process, Process, should be should be used used toto evaluate evaluate this finding.
this finding.
IfIf you you would like like to to discuss this this further, further, please please feel feel free free to contact contact me.
me.
Lois James, Lois James, Chief Chief PRA Operational Support (APOB)
Division of Risk Assessment (ORA) (DRA)
Office of Nuclear Reactor Regulation (NRR) 301-41 5-3306 301-415-3306 lois. ja lois. mes(nrc. qov james@nrc.gov 22
rov&cnJCn LV
" Franke,
- Franke, Mark Mark From:
From: Franovich, Rani Franovich, Rani Sent:
Sent: Friday, June Friday, June 04, 04, 2010 9:01 AM 2010 9:01 To:
To: Lubinski, John Lubinski, John Cc:
Cc: Rogers, Walt; Rogers, Walt; Vargas, Alexandra; Zoulis, Vargas, Alexandra; James, Lois; Zoulis, Antonios; James, Laur, Steven; Lois; Laur, Steven; Ashley, Ashley, MaryAnn; Circle, MaryAnn; Jeff; Franke, Circle, Jeff; Franke, Mark; Kennedy, Kriss; Mark; Kennedy, Kriss; Christensen, Sykes, Marvin; Harold; Sykes, Christensen, Harold; Marvin; Leonard; Munday, Wert, Leonard; Wert, Cheok, Michael; Joel; Cheok, Munday, Joel; Cunningham, Mark; Michael; Cunningham, Mark; Galloway, Melanie; Nease, Galloway, Melanie; Nease, Rebecca Rebecca
Subject:
Subject:
RE: St RE: St Lucie Lucie RCP RCP seal seal weld weld SDP SDP discussion discussion Attachments:
Attachments: Draft ROPFF Draft ROPFF forfor St St Lucie Lucie Importance:
Importance: High High Hey John, Hey John, Good seeing Good seeing you you yesterday. As II mentioned at at the Meeting, DIRS Supervisors' Meeting, the All Supervisors DIRS agrees Region Ils agrees with Region II's significance characterization significance characterization of of the St. involving the RCP lower finding involving St. Lucie finding lower cavity seal seal line J-weld failure.
line J-weld failure . We also agree with the sentiments also you expressed below sentiments you below and and recognize the need need to examine governing guidance.
examine governing guidance.
We have initiated aa feedback form form to capture learned and lessons learned capture lessons how and determine how and and where that guidance guidance can be clarified to ensure consistency/reliability. Paul ensure regional consistency/reliability. Paul forwarded thethe feedback form to to Walt (see (see attached) for his attached) his review before II approve.., just wanted folks approve ... just HQ and folks in HQ RII to be aware.
and Rll aware.
I'm sure you enjoyed Atlanta and RII; Im RIl; welcome back to HQ... HQ ... , I Rani TC)r L(S John From: Lubinski, John Friday, April 30, 2010 2:24 PM Sent: Friday, Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; To: Franovich, Lois; Laur, Steven; Ashley, MaryAnn; MaryAnn; Circle, Jeff Cc: Franke, Mark; Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Check, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca
Subject:
St Lucie RCP seal weld SDP discussion yesterday's conference call to discuss your perspectives on SOP My thanks to everyone for participating in yesterdays SDP treatment for a potential St. Lucie RCP seal weld leak finding.
After considering all views presented, and after additional discussion with Mark Franke, II believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licen's ee shutdown and entered reduced inventory operation. We did not identify performance deficiencies licensee associated with licensee shutdown operations or maintenance risk management as they affected repairs.
The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's residents quarterly report.
In addition, our review of this finding clearly demonstrates that our SOP SDP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's licensees actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. II will talk with NRRlOIRS NRRJDIRS about the next steps for such an examination.
11
Of. Franke, Mark Franke, Mark From:
From: Lubinski, Lubinski, John John Sent:
Sent: Friday, Friday, April April 30, 2010 2:24 30, 2010 2:24 PM PM To:
To: Franovich, Rani; Rogers, Walt; Franovich, Rani; Walt; Vargas, Alexandra; Zoulis, Vargas, Alexandra; Zoulis, Antonios; James, Lois; Antonios; James, Lois; Laur, Laur, Steven; Steven; Ashley, Circle, Jeff MaryAnn; Circle, Ashley, MaryAnn; Jeff Cc:
Cc: Franke, Kennedy, Kriss; Mark; Kennedy, Franke, Mark; Kriss; Christensen, Christensen, Harold; Marvin; Wert, Sykes, Marvin; Harold; Sykes, Leonard; Munday, Wert, Leonard; Munday, Joel; Check, Joel; Michael; Cunningham, Cheok, Michael; Mark; Galloway, Cunningham , Mark; Melanie; Nease, Galloway, Melanie; Nease, Rebecca Rebecca
Subject:
Subject:
St Lucie St Lucie RCP seal weld RCP seal SOP discussion weld SDP discussion My thanks My thanks to everyone for to everyone for participating in yesterday's conference in yesterdays conference call discuss your to discuss call to perspectives on your perspectives on SDP SDP treatment for aa potential potential St. Rep seal weld leak St. Lucie RCP leak finding.
After considering After views presented, considering all views presented, and after discussion with after additional discussion Franke, II believe Mark Franke, with Mark is consistent believe itit is our process with our process to move move forward to to treat treat this an At-Power finding. In as an this as other words, we In other would not we would not viewview this as aa finding warranting an as an Appendix Appendix G G risk risk assessment. To To perform maintenance maintenance to to correct the leak, the the leak, licensee shutdown licensee shutdown andand entered inventory operation.
entered reduced inventory operation. We We did did not performance deficiencies identify performance not identify deficiencies associated withwith licensee shutdown operations maintenance risk management as they affected repairs.
operations or maintenance repairs.
next steps The next action will be for Mark steps for this action Mark Franke to to provide input to DRP provide written input Branch 33 for inclusion DRP Branch inclusion inin next residents the next resident's quarterly quarterly report.
report.
demonstrates that our SDP procedures and processes need to be In addition, our review of this finding clearly demonstrates examined. As our guidance is currently written, aa number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on on whether itit was appropriate to include risk associated licensee's actions to fix the associated with the licensees leak. In leak. In the interests of program reliability, we believe that NRR should should examine whether changes are are needed needed to clarify or change our policy going NRRJDIRS about the next steps for such an going forward. II will talk with NRRlDIRS examination.
1
NRC FORM 757 NRC 757 U.S. NUCLEAR REGULATORY COMMISSION COMMISSION NRC MD NRC 10.158 MD 10.158 (3-2009)
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NON-CONCURRENCE PROCESS TITLE OF DOCUMENT I ADAMS ACCESSION NO. NO.
St. Lucie Inspection Report 05000389/2010003 SECTION 0: D: CONTINUATION CONTINUATION PAGE CONTINUATION OF OF SECTION D A D B B
D C NRC FORM NRC FORM 757 757 (3-2009)
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