ML18177A300

NRC-2018-000499 - Resp 1 - Final

ML18177A300
Person / Time
Issue date:	06/26/2018
From:	Stephanie Blaney NRC/OCIO
To:	Kolar J Government Accountability Project
Shared Package
ML18177A296	List: ML18177A300
References
FOIA, NRC-2018-000499
Download: ML18177A300 (71)

Text

NRC FORM 464 Part I U.S. NUCLEAR REGULATORY COMMISSION NRC RESPONSE NUMBER (04-2018)

RESPONSE TO FREEDOM OF 1 2018-000499 11 I INFORMATION ACT (FOIA) REQUEST RESPONSE TYPE D INTERIM I./ I FINAL REQUESTER: DATE:

!Jack Kolar 11 06/26/2018 DESCRIPTION OF REQUESTED RECORDS:

ML18019A140, EOC OE Note-2018; all records pertaining to the authoring of, review of, and response to ML18019A140; and all records pertaining to NRC-2018-000304 PART I. -- INFORMATION RELEASED The NRC has made some , or all , of the requested records publicly available through one or more of the following means:

(1) https://www.nrc.gov; (2) public ADAMS, https://www nrc.gov/reading-rm/adams.html; (3) microfiche available in the NRC Public Document Room ; or FOIA Online, https://foiaonline,regulations gov/foia/action/public/home.

0 Agency records subject to the request are enclosed.

Records subject to the request that contain information originated by or of interest to another Federal agency have been referred to D that agency (See Part I.D -- Comments) for a disclosure determ ination and direct response to you .

D We are continuing to process your request.

0 See Part I.D - Comments.

PART I.A -- FEES AMOUNT D You will be billed by NRC for the amount indicated.

D Since the minimum fee threshold was not met, you will not be charged fees.

D You will receive a refund for the amount indicated.

Due to our delayed response, you will not

[{J Fees waived . D be charged fees.

PART 1.B -- INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE D We did not locate any agency records responsive to your request. Note : Agencies may treat three discrete categories of law enforcement and national security records as not subject to the FOIA ("exclusions"). See 5 U.S.C. 552(c). This is a standard notification given to all requesters ; it should not be taken to mean that any excluded records do, or do not, exist.

0 We have withheld certain information pursuant to the FOIA exemptions described, and for the reasons stated , in Part II.

D Because this is an interim response to your request, you may not appeal at this time. We will notify you of your right to appeal any of the responses we have issued in response to your request when we issue our final determination.

0 You may appeal this fina l determination within 90 calendar days of the date of this response . If you subm it an appeal by mail, address it to the FOIA Officer, at U.S. Nuclear Regulatory Commission , Mail Stop T-2 F43, Washington , D.C. 20555-0001 . You may submit an appeal by e-mail to FOIA resource@nrc.gov. You may fax an appeal to (301 ) 415-5130. Or you may subm it an appeal through FOIA Online, https'//foiaoolioe regulations gov/foia/action/public/home. Please be sure to include on your submission that it is a "FOIA Appeal. "

PART I.C --REFERENCES AND POINTS OF CONTACT You have the right to seek assistance from the NRC's FOIA Public Liaison by submitting your inquiry at https://www.nrc.gov/reading-rm/

foia/contact-foja html , or by calling the FOIA Public Liaison at (301) 415-1276.

If we have denied your request, you have the right to seek dispute resolution services from the NRC's Public Liaison or the Office of Government Information Services (OGIS). To seek dispute resolution services from OGIS , you may e-mail OGIS at ogis@nara.gov, send a fax to (202) 741-5789, or send a letter to: Office of Government Information Services, National Archives and Records Administration ,

8601 Adelph i Road , College Park, MD 20740-6001 . For additional information about OGIS , please visit the OGIS website at bttps'//www archives,gov/ogis.

NRC FORM 464 Part I U.S. NUCLEAR REGULATORY COMMISSION NRC RESPONSE NUMBER RESPONSE TO FREEDOM OF 1 201 s-000499 11 I INFORMATION ACT (FOIA) REQUEST RE~~~SE D INTERIM I./ I FINAL PART I.D -- COMMENTS Please note that, upon receipt of your request, we conducted another review of ML18019A140, and it was determined that additional information could be released than what had been released in the final response to FOIA request, NRC-2018-000304, which is publicly available at ML18057A007.

Signature - Freedom of Information Act Officer or Designee Digitally signed by Stephanie A. Blaney

!Stephanie A. Blaney Date: 2018.06.26 07:01 :45 -04'00'

NRC FORM 464 Part II U.S. NUCLEAR REGULATORY COMMISSION NRC (04-2018)

RESPONSE TO FREEDOM OF 1 2018-000499 INFORMATION ACT (FOIA) REQUEST DATE:

1 06,26,2018 PART II.A -- APPLICABLE EXEMPTIONS Records subject to the request are being withheld in their entirety or in part under the FOIA exemption(s) as indicated below (5 U .S .C . 552(b)).

D Exemption 1: The withheld information is properly classified pursuant to an Executive Order protecting national security information.

D Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRC.

D Exemption 3: The withheld information is specifically exempted from public disclosure by the statute indicated .

D .Sections 141 -145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42 U.S.C. 2161-2165).

D Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

D 41 U.S.C. 4702(b), which prohibits the disclosure of contractor proposals, except when incorporated into the contract between the agency and the D Other:

Exemption 4: The withheld information is a trade secret or confidential commercial or financial information that is being withheld for the reason(s)

D indicated.

The information is considered to be proprietary because it concerns a licensee's or applicant's physical protection or material control and D accounting program for special nuclear material pursuant to 10 CFR 2 .390(d)(1) .

[Z] The information is considered to be another type of confidential business (proprietary) information.

[Z] The information was submitted by a foreign source and received in confidence pursuant to 10 CFR 2 .390(d)(2).

[Z] Exemption 5: The withheld information consists of interagency or intraagency records that are normally privileged in civil litigation .

[ZJ Deliberative process privilege.

D Attorney work product privilege.

D Attorney-client privilege.

[71 Exemption 6: The withheld information from a personnel , medical, or similar file, is exempted from public disclosure because its disclosure would result L!'..J in a clearly unwarranted invasion of personal privacy.

D Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated.

D (A) Disclosure could reasonably be expected to interfere with an open enforcement proceeding.

D (C) Disclosure could reasonably be expected to constitute an unwarranted invasion of persona l privacy.

(D) The information consists of names and other information the disclosure of which could reasonably be expected to reveal identities of confidential D sources.

(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be D expected to risk circumvention of the law.

D (F) Disclosure could reasonably be expected to endanger the life or physical safety of any individual.

D Other:

PART 11.B -- DENYING OFFICIALS In accordance with 10 CFR 9.25(g) and 9.25(h) of the U.S. Nuclear Regulatory Commission regulations, the official(s) listed below have made the determination to withhold certain information responsive to your request.

APPELLATE OFFICIAL DENYING OFFICIAL TITLE/OFFICE RECORDS DENIED EDO SECY 1 1 personally identifiable, foreign-sourced, Stephanie Blaney 11 FOIA Officer proprietary and predecisional/deliberative information 0 D I 11 Select Title/Office from drop-down list 11 I D D I 11 Select Title/Office from drop-down list 11 I D D

Select Title/Office from drop-down list I

D D I I I NRC Form 464 Part II (04-2018)

Robles-Alcaraz, Jesse From: Thompson, John Sent: Thursday, April 26, 2018 11:22 AM To: Robles -Alcaraz, Jesse

Subject:

FW: End of Cycle OpE Note In response to the FICA.

john From: Thompson, John Sent: Thursday, January 11, 2018 3:29 PM To: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nr c.gov>

Subject:

RE : End of Cycle OpE Note Made a few edits on the test box article (in red) .

john From: Robles-Alcaraz, Jesse Sent: Thursday, January 11, 2018 3:09 PM To: Thomas, Eric <Eric.Thomas@nrc.gov>; Thompson, John <John.Thompson@nrc.gov>; Sigmon, Rebecca

<Rebecca .Sigmon@nrc.gov>; Carneal, Jason <Jason.Carneal@nrc.gov>; Pannier, Stephen <Stephen.Pannier@nrc.gov>

Subject:

RE: End of Cycle OpE Note I haven't received any comments . Please provide comments by COB on Monday. I hope to get the note out next Wednesday.

Thanks, Jesse E. Robles U.S . Nuclear Regulatory Commi ssion Reactor Systems Engi neer NRR/DIRS/JOEB 301 -4 15-2940 301 -4 15-306 1 (fa x)

Jesse.Rohles@Jrrc.gov From: Thomas, Eric Sent: Monday, January 08, 2018 4:23 PM To: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nrc.gov>; Thompson, John <John .Thompson@nrc.gov>; Sigmon, Rebecca <Rebecca .Sigmon@nrc.gov>; Carneal, Jason <Jason.Carneal@nrc.gov>; Pan nier, Stephen

<Stephen.Pannier@nrc.gov>

Subject:

End of Cycle OpE Note Please see attached and provide any comments to Jesse .

It's located under G:\ADRO\DIRS\IOEB\Subject Folders\OpE Products\OpE Notes\End of Cycle Feb 2018 Thanks. Eric Eric Thomas NRR/DIRS/IOEB r

301-415-6772

6) * ' (mobile) 2

!DRAl,1'!

DO NOT FORWARD ANY EXCERPTS OUTSIDE OF NRC WITHOUT FIRST OBTAINING PERMISSION FROM ORIGINATOR Operating bperience Note January 2018

b)(5) b) 5) b)(5)

(b)(5)

(b)(5) l(b)(5) b)(5)

From: Sigmon Ret>e<;ca To: Elliott Bot>ert

• Robfes-Atcacaz Jesse Cc: Thomas Ede

Subject:

RE: OpE End of Cycle lnput Date: Thursday, January 18, 2018 9:51:39 AM How's this?

(Updated bullets with questions to ask)

• Does the procedure meet the code requirements?

• Are the personnel performing the examinations following the procedure?

• Are contractors/vendors adequately trained on licensee expectations for procedure adherence?

• Is there an adequate level of independence between data analysts comparing examination results to acceptance criteria?

• Are indications appropriately characterized and compared to previous examination results?

• Is the licensee providing adequate, knowledgeable oversight of examinations performed by contractors?

From: Elliott, Robert Sent: Thursday, January 18, 2018 8:58 AM To: Sigmon, Rebecca <Rebecca.Sigmon@nrc.gov>; Robles-Alcaraz, Jesse <J esse.Robles-Alca raz@nrc.gov>

Cc: Thomas, Eric <Eric.Thomas@nrc.gov>

Subject:

RE: OpE End of Cycle Input I wasn't focused on the takeaways as much as I was on the relevant inspection procedures. In that section, we provide some suggested questions t e i spector might ask. I was thinking we should ask some questions about contractor oversight (i it's applicable to the procedure listed).

From: Sigmon, Rebecca Sent: Thursday, January 18, 2018 8:43 AM To: Elliott, Robert <Robert Elliott@nrc.~ov>; Robles-Alcaraz, Jesse <Jesse Rob!es-A!caraz@nrc gov>

Cc: Thomas, Eric <E ric Thomas@nrc gov>

Subject:

RE: OpE End of Cycle Input There were two main takeaways from thL__J eport . Jbl!4ll One is that the licensee is responsible for providing effective oversight of contractor activities - the performance of the job, and the documentation of the resu lts. rb)(4) (b)(S)

(b)(4) (b 5)

rb1(4) (bl(5)

I'll tweak the write-up a bit so it's clear and make sure the language conforms with IP 71111 .08.

Rebecca From: Elliott, Robert Sent: Thursday, January 18, 2018 8:33 AM To: Robles-Alcaraz, Jesse <Jesse Robles-Alcaraz@nrc,eov>

Cc: Thomas, Eric <Eric.Thomas@nrc gav>; Sigmon, Rebecca <Rebecca 5i800Po@orc gav>

Subject:

RE: OpE End of Cyde Input Should we spell it out more completely in the suggestions for the inspector? lo me, a ind pendent review means you have someo e outside the o ganization review t e work In thi s case, it appears to be mo e o a lack of adequate cor,tractor oversight by the licensee.

From: Robles-Alcaraz, Jesse Sent: Thursday, January 18, 2018 8:11 AM To: Elliott, Robert <Robert Elliau@orc gov>

Cc: Thomas, Eric <Eric Jhamas@nrc.gov>; Sigmon, Rebecca <Rebecca s*fl[')an@nr c eov>

Subject:

FW: OpE End of Cycle Input Rob, The answer to your question is yes. We've pulled the thread on licensee's inadequate oversight of contractors and vendors in the past (e.g., IN 2016-07, although this was focused on electrical issues). See Rebecca's (who authored the article) more detailed answer below Thanks, Jesse From: Sigmon, Rebecca Sent: Thursday, January 18, 2018 7:10 AM To: Robles-Alcaraz, Jesse <Jesse.Robles-A!caraz@nrc gov>

Subject:

RE: OpE End of Cycle Input (b) 4) (b (5)

I would say yes.

l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __J

(b)(4) (b)(51 From: Robles-Alcaraz, Jesse Sent: Thursday, January 18, 2018 6:53 AM To: Sigmon, Rebecca <Rebecca Sicmon@nrc,goy>

Subject:

FW: OpE End of Cycle Input 1tb)(4) I See Rob's question on th1L_ _ ___,wnte-up. Thoughts?

From: Elliott, Robert Sent: Wednesday, January 17, 2018 7:28 PM To: Robles-Alcaraz, Jesse <Jesse.Robles Alcaraz @orc gov>

Cc: Thomas, Eric <Eric Jhomas@nrc IWY>

Subject:

RE: OpE End of Cycle Input Jesse, th lib 4) (

This looks good. I only have one question/comment. 0 ~ we suggest hat the inspector consider w ether there is sufficient independent review o the contractor's work. Is this the same as asking i the licensee is maintaining adequate oversight of the contractor's work (e.g.,

did the licensee evaluate the contrac or's procedure, watch the contractor perform some o their weld inspections (spot check), or review any of the contractor's results?

Thanks !

Rob From: Robles-Alcaraz, Jesse Sent: Wednesday, January 17, 2018 10:53 AM To: Elliott, Robert <Robert E:H;ott@nrc gov>

Cc: Thomas, Eric <Eric.T homas@nrc gov>

Subject:

OpE End of Cycle Input

Rob, Attached is the OpE Input for the End of Cycle assessment meetings. The topics in the OpE Note are what the branch briefed during the inspector counterpart meetings. Please review and let me know if you have any comments or changes by Friday, since I'd like to

have this out to the regions soon to allow them some time to review before the EOC meetings in early February.

Thanks, Jesse E. Robles U .S. Nuclear Regulatory Commission Reactor Systems Engineer NRR/DIR.S/JOEB 301-415-2940 301-415-3061 (fax)

Jesse, RobJanrc.gov

Robles-Alcaraz, Jesse From: Sigmon, Rebecca Sent: Thursday, January 18, 2018 9:54 AM To: Robles-Alcaraz. Jesse

Subject:

OpE Note Just the two noted changes at the bottom of the last page.

Rebecca Sigmon Reactor Systems Engineer NRR/DIRS/IOEB I1301) 415-0895 b)(6)

(M,W,F) l(T,Th)

Robles-Alcaraz. Jesse From: Robles-Alcaraz, Jesse Sent: Friday, January 19, 2018 10:09 AM To: Bell, Keyona Cc: Thomas, Eric

Subject:

Document for ADAMS Attachments: EOC OE Note-2018.pdf; NRC 665.pdf

Keyona, Can you please add the attached document to ADAMS? Let me know if you have any questions.

Thanks, Jesse E. Robles U.S. Nuclear Regulatory Commission Reactor Systems Engineer NRR/DIRS/IOEB 301-415-2940 301-415-3061 (fax)

Jesse.Roble5@nrc.gov 1

DO NOT FORWARD ANY EXCERPTS OUTSIDE OF NRC WITHOUT FIRST OBTAINING PERMISSION FROM ORIGINATOR Operating bperience Note January 2018 End ol CVcle Operating Experience Update, 2018 Introduction and Philosopbv The purpose of this report is to provide the regions with insights into recent themes that have been noted by Headquarters Operating Experience (OpE) staff and our regional points of contact. This report focuses issues that are tied to recent trends in OpE and have a nexus to one or more in-spection modules. This report is intended to provide information that will better inform the inspec-tion program.

Additional Operating Experience Branch staff observations and event summaries can be found in our Periodic Operating Experience newsletters, which we circulate every few months; in other Operating Experience Notes, which we produce in response to specific inquiries; and in Operating Experience Communications . All of our products are located on the OpE Sharepoint Portal.

We encourage recipients and users of this report to provide feedback directly to Jesse Robles or Eric Thomas.

Oil Sight Glass Events Eric Thomas and John Thompson Summary On September 13, 2017, during an auxiliary feedwater pump (AFW) quarterly surveillance run , the licensee at Davis Besse noted high temperatures on the AFW turbine inboard bearing. Operators tripped the pump, and investigation revealed bearing damage , which was attributed to a lack of lubri-cation caused by insufficient level in the oil res-ervoir. The staff issued an Operating Experi-ence OpE Communication (COMM) describing the event at Davis Besse. The COMM includes discussions of other similar events where oil levels in various components were inaccurately indicated on sight glasses for a variety of differ-ent reasons.

Discussion The staffs investigation of the AFW turbine bearing event at Davis Besse revealed that the event most likely occurred because of operator workarounds and inadequate application of vendor guidance for properly measuring oil lev-Davis Besse Failed Inboard Bearing el. The minimum level mark on the sight glass was lower than what was described in the ven-dor manual. Operators had recently drained 10-11 ounces from the oil reservoir for a sample . Since level was still above the low level mark on the sight glass, they did not replenish the oil. This caused oil level to remain below that required for the turbine's slinger rings to effectively lubricate the inboard bearing, and resulted in excessive bearing damage (see figure 1).

A review of the vendor guidance for the AFW pump ~nd turbine revealed specific instructions for set-ting the oil sight glass minimum and maximum levels. The band described in the guidance requi red oil level to read higher on the sight glass, and required oil level to be maintained within a tighter band than what the licensee was using . There were marks that had been painted on the turbine casing that showed a narrower band, but the as-found oil level was significantly below these marks (see figure 2).

I I Oil Sight Glass Events (cont'd)

After performing an OpE search, the staff uncovered oth-er instances of performance issues related to oil sight glasses. These are discussed in detail in the OpE COMM:

• AN0-2 (2016) - EOG inboard generator bearing failed from lack of lubrication . The sight glass was inverted by workers during post-surveillance reinstal-lation which led to low oil level.

• Hope Creek (2009) - HPCI booster pump outboard .

bearing oil level was below the minimum level mark (b) 5) with oil leaking from the sight glass housing threaded connection. Procedural guidance and other operator aids were insufficient to ensure proper oil level was maintained .

• Beaver Valley (2001 ) - AFW pump outboard bearing oil level sight glass did not have sufficient markings for high/low oil level.

Inspector Takeaways Figure 2: Davis Besse As-Found O il Level The OpE COMM contains several tips for inspectors as they perform plant walkdowns or inspections of systems using oil sight glasses or bubblers. In summary, inspectors should look for:

• Evidence that the licensee's methods for assuring proper oil level using a sight glass is based on procedural guidance and vendor recommendations, and limits reliance on skill of the craft or other operator walkarounds.

• Potential leaks from oil sight glasses.

• Sight glasses that may have been installed upside down , rendering the level markings inaccurate.

• Air flow in the vicinity of sight glass ven ts which can cause erroneous level readings.

Previous Operating Experience

• Information Notice (IN) 81 -24 , "Auxiliary Feed Pump Turbine Bearing Failures"

• IN 2008-09, "Turbine-Driven Auxiliary Feedwater Pump Bearing Issues" Relevant Inspection Procedures

• IP 71111 .12, "Maintenance Effectiveness"

• IP 71111 .21 M, "Design Basis Assurance Inspections"

• IP 71152, "Problem Identification and Resolution" Additional Actions The staff is in the process of writing an information notice to communicate th is issue to stakeholders.

RPS Test Box John Thompson Summary Unk to OpE COMM:

In recent months, there have been several instances where Boiling Water Reactor (BWR) licensees "Fermi - RPS Test Box" did not enter the correct Technical Specification (TS) Action Statement durin uarter1 surveillance testing of the reactor protection system (RPS) logic. These issues b) 5 i1b)(5) LOyster Creek in August of 2017, and Fermi in Septemb"'e-r'"'o.,.,,2"'

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la_n_ce testing of RPS logic strings for the closure function of the Turbine Stop Va lves (TSVs) and Main Steam Isolation Valves (MSIVs).

RPS Test Box ( cont'd)

Discussion Most BWR designs have four RPS trip channels (A 1, A2, B 1, and B2) and two RPS trip systems (A and B) . Each channel is capable of producing a half scram by satisfying the one out of two logic required to actuate a trip system. A reactor trip (full scram) occurs if the one out of two logic is satisfied on each of the two trip systems (i.e., at least one MSIV in 3 of 4 main steam lines close , or 3 of 4 TSVs close). During typical RPS quarterly surveillance testing, one channel is placed in test in order to con-duct the surveillance test. Placing any one of the four channels in test generates a half scram , leaving any of the other three channels available to generate a full scram . While this arrangement is conserva-tive, the practicality of this situation means a licensee is at heightened risk of experiencing a full scram during the surveillance activity. In order to reduce this risk, industry-based initiatives by the Boiling Wa-ter Reactor Owners Group (BWROG) have been underway since 2008 to reduce the number of pre-ventable scrams. One solution resulting from this initiative is the use of a device that prevents genera-tion of a half scram during RPS logic testing. Specifically, a "RPS Test Box" is used in similar fashion as an electrical jumper, but is designed to allow monitoring of the contact state while maintaining electri-cal continuity across the contact(s) being tested . This configuration thus prevents the generation of a half-scram signal when the contacts are opened (de-energized) during surveillance testing .

When used in MSIV and TSV RPS logic surveillances, the RPS Test Box is installed across contacts that are arranged in parallel (see Figure 3). Doing so removes multiple contacts from the circuit, and impacts the ability to meet the TS requirement for both trip systems to have each channel associated with the MSIVs in 3 main steam lines either operable or in trip, or for both trip systems associated with the TSVs to have 3 channels either operable or in trip. With the RPS Test Box installed across multiple contacts, 2 of 4 main steam lines become inoperable, rendering the MSIV closure function (and similarly for the TSV closure function) not maintained. This requires the licensee to enter a TS Condition requir-ing action to restore trip capability within one hour. In the case of Fermi , the test box was installed for less than an hour, but the licensee did not enter the TS Condition. At TUT fWITC H A Oyster Creek , the licensee had the RPS Test Box in-stalled for greater than the one hour allowed by TS.

For most BWRs, use of the RPS Test Box is a change in testing that requires a formal 10 CFR 50.59 evalua-tion . Following its realization that use of the RPS Test RPS Test Box Jumper Box would require entry into a TS action statement for trip Connection Points functions involving parallel logic strings, Fermi-2 revised its procedures to discontinue use of the RPS Test Box.

IOEB staff is drafting an information notice on this issue.

JIJCllAft IVlfUI HtoH *"1aa,flt Inspector Takeaways Inspectors should maintain a questioning attitude if they A MAtw ITIAM UNI become aware that their licensee is using a RPS Test MtOH AADIATION Box during surveillance testing . If the licensee is using A} ljlU'TIIONlitONlfCHII the RPS Test Box, inspectors should determine :

l'flflM I *

• Did the change require a 50.59 evaluation and was the evaluation performed?

IIIACTOR PftOTICTION IYIT LOGIC

• Whether use of the RPS Test Box involves bypassing any contacts that are arranged in parallel.

• Whether the plant should be entering any TS condi-tions when using the RPS Test Box

• Whether the licensee is aware of BWROG Recom-mendation 30, along with existing industry OpE relat-ed to use of the RPS Test Box.

Figure 3: Ferml -2 RPS Trip System Logic Showing location of RPT Test Box for Relevant Inspection Procedure MSIV Surveillance Testing

• 71111 .18, "Plant Modifications Additional Staff Actions Staff is in the process of drafting an IN to communicate this issue with stakeholders.

Waterford 3 Loss of Offsite Power (LOOP) Event By Steve Pannier Summary On July 17, 2017, during a rain and lightning event, plant operators at Waterford 3 manually tripped the main turbine and generator based on a report of arcing being observed from a main transformer iso-phase bus duct. This resulted in an automatic reactor cutback . After the main turbine and generator trip, the circuit breakers associated with the unit auxiliary transformers (UATs) automatically opened, but the circuit breakers for the startup transformers failed to automatically close as designed. This re-sulted in the de-energization of all safety and non-safety AC buses. The reactor coolant pumps tripped , Link to Waterford 3 causing an automatic reactor trip on a loss of forced circulation. Both emergency diesel generators OpECOMM (EDGs) started as designed and reenergized the safety buses . Waterford 3 declared an Unusual Event (UE) based on a loss of offsite power lasting longer than 15 minutes (See EN 52863 ). Four hours later, the licensee exited the UE after successfully shifting loads from the EDGs to the startup transformer. Link to Waterford 3 Ucens<< Event Report Discussion The licensee determined an apparent cause of the initiating event to be loose bolted connections asso-ciated with laminated flex links, which resulted in high electrical currents and the eventual failure of the isophase bus duct. During the ensuing special inspection , NRC inspectors found that the licensee did Link to Waterford 3

• not perform adequate preventive maintenance consistent with site requirements to identify the loosen-ing connections prior to failure. The NRC has also issued previous generic communications on the Importance of maintaining tight bolted connections.

• Information Notice (IN) 2010-25, "Inadequate Electrical Connections"

• IN 2000-14 , "Non-Vital Bus Fault Leads to Fire and Loss of Offsite Power" The root cause for the failure of the fast transfer of electrical loads from the UATs to the startup trans-formers was the failure of the installed Struthers-Dunn time-delay relays in the fast transfer circuitry.

When the UATs lost power, the subsequent de-energization of the 152X relay produced a large change in voltage that, because surge suppression was not utilized, caused the Struthers-Dunn relays to in-stantaneously time out and open their contacts. The absence of any time-delay prevented the fast bus transfer to the startup transformers. The Struthers-Dunn relays were installed during the licensee's April 2017 refueling outage. Prior to their installation , Allen Bradley time-delay relays were used, which contained integrated surge suppression . The surge suppression allowed the Allen Bradley time-delay relays to mitigate the voltage transient produced by the 152X relay, which permitted the fast bus trans-fer to operate successfully.

The licensee considered the root cause of the fast bus transfer failure to be a deficient design change modification implemented on the fast bus transfer circuitry to replace the Allen Bradley time-delay re-lays with Struthers-Dunn time-delay relays . That design change did not consider surge suppression as a critical relay characteristic. Commercial grade dedication, including the importance of considering all of a component's critical design characteristics, Is discussed in two recent NRC Information Notices:

• IN 2016-01 , "Recent Issues Related to the Commercial Grade Dedication of Allen-Bradly 700-RTC Relays*

• IN 2016-09, "Recent Issues Identified When Using Reverse Engineering Techniques in the Pro-curement of Safety-Related Components" Figure 4: Image of Struthers-Dunn Relays lnstaHed at Waterford 3

Waterford 3 Loss of Offsite Power (LOOP) Event ( cont'd)

Inspector Takeaways The root and contributing causes for this event are both issues that are well-known and have been fo-cused on by NRC's operating experience and quality assurance centers of expertise in the past few years. The event initiator was a loose electrical connection which caused a fault. Loose electrical con-nections have been covered in recent NRC generic communications and event inspections. Likewise, commercial grade dedication is a vulnerability that has been the root or contributing cause of several events recently.

• Inspectors can follow up on their licensee's disposition of industry operating experience and NRC generic communications pertaining to electrical connections.

• Inspectors can review their licensee's commercial grade dedication program . A good question to ask is how does the licensee ensure that they are including all critical characteristics when per-forming like for like piece-part replacements.

Previous Operating Experience (see NRC information notices listed on previous page)

Relevant Inspection Procedures

• IP 71111 .18, "Plant Modifications"

• IP 43004, "Inspection of Commercial-Grade Dedication Programs" Additional Actions l(b)(5)

Jrb}l5)

EDG Voltage Regulator Diode Failures By Jason Carneal Summary Operating Experience staff recently published an OpE COMM summarizing a number of diode failures Link to OpE COMM on since 2010 which have adversely impacted the operability of EDGs. These diodes are located in the EOG &citation futem Diodes generator excitation system, which monitors generator output, and varies the strength of the magnetic field to maintain proper voltage. Most recently, in April 2017, diode CR4 in the EOG excitation circuit of the 2A EOG at Catawba Unit 2 short-circuited , causing the EOG to trip during a monthly surveillance test. The design of the generation excitation circuit, combined with numerous instances of operating experience pointing to the potential for early failure of the diode, should have prompted the licensee to have a more rigorous monitoring and replacement program in effect for these components.

Discussion Catawba Following the short-circuit of the diode at Catawba Unit 2, the licensee replaced all 6 of the diodes in along with 3 shunting thyristors in the rectifier circuit and power-driven potentiometer. Further analysis of the issue by NRC inspectors revealed a known design issue wherein certain diodes in the generator excitation circuit remain in an energized state for long periods of time, and are therefore subjected to elevated operating temperatures (as much as 60 deg F higher than other diodes in the circuit) . These conditions can shorten diode life and lead to premature failures if the diodes are not replaced on a more frequent basis . Catawba had experienced previous failures of the CR4 diode, along with other diodes subjected to the elevated temperatures. In addition, the licensee had screened other operating experi-ence related to diode failures into its corrective action program , including:

• NRC IN 2005-15, "Three Unit Trip and Loss of Offsite Power at Palo Verde Nuclear Generating Station"

• l(b)(4)

EOG Voltage Regulator Diode Failures (cont'd)

The IN briefly mentions an EDG failu a ma*or LOOP event at Palo Verde. (b)(4)

Catawba Catawba received a White inspection finding under TS 5.4.1, ro""c""e""""

ur"e

"""s~ o""'r"!:en~or-e"'s"'a

= ""

1s~ ,n"!:e g-:a'"'p"'r,.,,.

e~ ventive maintenance program for the EDG excitation system ,

and an associate violation of Appendix B Criterion XVI for failure to correct a condition adverse to quali-ty associated with elevated operating temperatures of EDG excitation system diodes.

Wolf Creek In October 2014, during a 24-hour surveillance test, Wolf Creek's 'B' EDG tripped due to a fire in the electrical excitation control cabinet. The source of the fire was the power potential transformer (PPT).

The PPT became overloaded because of two failed diodes in the EDG's current transformer (CT). Link to OpE COMM on When these diodes failed , the current boost to the EDG excitation field was reduced , and the voltage Wolf CrttJs EDG faitulre regulator compensated by increasing the output of the PPT. This exceeded the load capability of the PPT, and over lime it eventually failed .

• The CT di-odes had likely failed during a previous surveillance run in June 2014 . Operators had noticed smoke coming from the PPT during interim monthly runs ,

but it wasn 't until the 24-hour endurance run that conditions worsened lo the point of PPT overheating and failure . The licensee had planned to replace the PPT in August 2014, but the replacement was de-layed until February 2015.

The staff intends to issue an Information Notice sum-marizing these and other similar events .

Inspector Takeaways Our domestic fleet of nuclear reactors includes many plants operating near or beyond their original 40-year licenses. These plants have numerous compo-nents installed that were either designed for the 40- Figure 5: Failed PPT at Wolf Creek year life of the plant or do not have a defined service life. These realities make it increasingly important for licensees to 1) follow up on operating experience regarding the reliability of safety-related compo-nents, and 2) take timely corrective action when they discover equipment that is at or near end of life.

Continuous review of the licensee's corrective action program, along with periodic inspections of prob-lem identification and resolution are two main methods inspectors can use to ensure licensees are iden-tifying and fixing conditions adverse to quality.

Previous Operating Experience (see NRC information notice, OpE COMMs , and INPO' s Event Report listed above.

• Relevant Inspection Procedures

• IP 71111 .12. "Maintenance Effectiveness*

• IP 71152, "Problem Identification and Resolution "

Additional Actions

l..,..- - - - - - - - - -Iand Contractor Oversight (b/(4)

Rebecca Sigmon Summary (b)(4) r Link to QpE coMj on 4)

Discussion l(b)(4)

I I

I I

I I

I

.r_. 141

_ _ _ _ _ _ _ _ _...,!and Contractor Oversight (cont'd)

Inspector Takeaways The OpE COMM linked on the previous page contains several examples of inspection reports with find-ings related to difficulties encountered by U.S *

• CJ Previous Operating Experience

• OpE COMM, "Arkansas Nuclear One Stator Drop"

• OpE COMM, "Licensee Oversight of Contractor and Vendor Activities"

• IN 2016-07, "Operating Experience Regarding Impacts of Site Electrical Power Distribution From Inadequate Oversight of Contractor Activities."

Relevant Inspection Procedures

• IP 71111 .08, "In service Inspection (ISi) Activities,"

• IP 73054,"Part 52, Preservice And lnservice Inspection - Review Of Program"

• IP 65001 .3, "Inspection of ITAAC-Related Installation of Piping" When performing inservice inspection activities, inspectors should consider the following questions:

• Does the procedure meet the code requirements?

• Are the personnel performing the examinations following the procedure?

• Are contractors/vendors adequately trained on licensee expectations for procedure adherence?

• Is there an adequate level of independence between data analysts comparing examination resu lts to acceptance criteria?

• Are indications appropriately characterized and compared to previous examination results?

• Is the licensee providing adequate, knowledgeable oversight of examinations performed by con-tractors?

NRC FORM 665 / \ U.S. NUCLEAR REGULATORY COMMISSION (01-201s1 1 > a ADAMS DOCUMENTSUBM~S~N

\;, ,,.,, '/ Instructions for completing NRC Form 665 - "Cheat Sheet" (ML15313A3.10)

Document Owner Originated By Phone No. (Enter 10 digits) Mail Stop LAN ID Date Jesse Robles Jesse Robles (301) 415-2940 jxr8 01/19/2018 If documents are to be put into a package and have the same release properties, list the Document Titles or Accession Numbers below in the order they should appear. Documents with different release properties and sensitivity levels should be listed on additional forms in the order they should appear. Examples (ML16035A181J Note: Document Owner is solely responsible for setting the Availability, Document Sensitivity and Document Security Access Level.

Document No. Total Number of Documents in this package Document Title(s) or Accession No.

2018 OpE Input for End-of-Cycles OEN Package Title (if necessary):

Is this a brief title that can be changed by DPC according to template instruction?

0 Yes D No SUNSI Review has been completed (for Publidy Available Documents)

D Yes D No IInitials Document AVAILABILITY (select one)

Publicly Available [Z] Non-Publicly Available MD 3.4 Non-Public Item Code (A.3-A.7,B1)

(Indicate Release Date) Document SENSITIVITY (select one)

D Immediate Release I@ IA.1 ISensitive Internal Info - Periodic Review Required (all other ID IA. 4 ISensitive Proprietary D Normal Release sensitive internal info)

D Delay Release Until ID IA? I Sensitive Internal Info - No ID IA. 3 I Sensitive-Security Periodic Review (attorney work Related - Periodic product & client privilege, and Review Required Date pre-decisional enforcement)

D Non-Sensitive ID IA. 6 I Gov't, Sensitive - Fed , State , Foreign International Agency ID I 8

• 1 I Non-Sensitive D Non-Sensitive Copyright Controlled Info Note: Package to be marked for release if two or more documents within the package ID I A. 5 ISensitive - PNPII (includes Personally Identifiable ID 1s.1 I Copyright Non-Sensitive -

are publicly available Information (PII))

Document SECURITY ACCESS LEVEL 10 Document Processing Center I=Owner I ID NRC Users I= V iewer I D Limited Document Security (Defined by Group or User e.g., Joe Smith= Owner)

Package Accession No. ADAMS Template No. RIDS Code (if applicable) Other Identifiers Special Instructions Submitted By Phone No. (Enter 10 digits) Mail Stop LANID Date Submitted to DPC ML020170279 Page 1

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHI GTO , D.C. 20555.0001 January 24, 2018 NRC 2018 000304 Paul M. Blanch

Dear Mr. Blanch:

We received your Freedom of Information Act (FOIA) request on January 24, 2018.

Your request, which seeks access to ML18019A140, EOC OE Note-2018, has been assigned the following reference number that you should use in any future communications with us about your request: NRC 2018 000304.

To ensure the most equitable treatment possible of all requesters, the NRC processes requests on a first-in, first-out basis, using a multiple track system based upon the estimated time it will take to process a request. Based on your description of the records you are seeking, we estimate completion of your request will be on or before February 22, 2018.

Please know that this date roughly estimates how long it will take us to close requests ahead of yours In the respective track and complete work on your request. The actual date of completion might be before or after this estimate, based on the complexity of all of the requests In the simple. We will advise you of any change in the estimated time to complete your request. In an effort to process your request promptly, you may wish to narrow the scope of your request to limit the volume of potentially responsive records.

For purposes of assessing fees in accordance with our regulations (10 CFR 9.33), we have placed your request in the following category: Non Excepted. If applicable, you will be charged appropriate fees for: Search & Duplication of Records.

A sheet has been enclosed that explains in detail the fee charges that may be applicable.

Please do not submit any payment unless we notify you to do so.

The following person is the Government Information Specialist who has been assigned responsibility for your request: Gabriele Chidichimo at 301-415-6968 or Gabriele.Chidichimo@nrc.gov.

If you have questions on any matters concerning your FOIA request, please feel free to contact the assigned Government Information Specialist or me at (301) 415-7169.

Sincerely, Stephanie A. Blaney FOIA Officer Office of the Chief Information Officer

Enclosures:

Explanation of Fees

EXPLANATION OF FEES Regueater Fee Categories Commercial: Fees are charged for document search, duplication. and review. when records are requested for commercial purposes. Fees (above the minimum fee charge) cannot be waived for this category of requester.

Educatlonal. Non-Commercial Sc:lentlflc, News Media and Privacy Act: Fees may be charged only for document du plication when records are not sought for commercial use and the request is made by an Educational or Non-Commercial Scientific Institution. whose purpose is scholarly or scientific research; or a Representative of the News Media; or a person requesting his/her own records that are in a Privacy Ad system of records. No fee is charged for the first one hundred pages of duplication for this category of requester.

Non-Excepted: For any request not desO'ibed above (Non-E,ccepted), fees may be charged for document search and duplication. No fee Is charged for the first two hours of search time or for the first one hundred pages of duplication for this category of requester.

FMSchedulea Fee schedules provide only for the recovery of the direct costs of search, duplication, or review. Review co ts include only the costs for lnlUel examination of a document to determine whether it must be dlsclosed and to detennlno whether lo withhold portions that are exempt from disclosure. The fee schedule Is as follows:

Search & Review Conducted By Bl!!

I SES/COMMISSIONER $90.53/hour (ES-maximum)

I PROFESSIONAL $56.36/hour (GG-13, Step 6) 1 CLERICAL $25.16/hour (GG-7, Step 7)

~ull!lcatlon Charms $.20 per page Fees for non-standard search or duplication wlU be charged at the actual cost (e.g. providing copying of audio tapes or conducting computer searches).

Minimum Fee: No fee will be charged unless the fee is equal to or greater than $25.00.

When to Pay Fees If we estimate that fees will not exceed $25.00 or you have stated in your request a higher amount that you are willing to pay, we assume your willingness to pay up to $25 or the amount stipulated and you wll be billed after we have completed your request.

If we estimate that fees will exceed $25.00 or any amount that has been stated by you In your request, we wlN not proceed with your request until we have notified you and obtained your agreement to pay the estrnated fees.

If we estimate fees will exceed $250, you will be required lo pay the estimated fees In advance before we proceed further with your request. If, while processing your request, we find that the actual fees exceed the estimated fee, we will obtain your consent to pay the additional fees before continuing to process your request. If the actual fees to process your request are less than any advance payment you have made, you will be refunded the overpayment amount.

Fee Waivers A waiver or reduction of fees may be granted for furnishing documents If a requester, by fully addressing the eight factors In 10 CFR g,41, clearly demonstrates that disclosure of the lnfonnation is In the public Interest because it Is Nkely to contribute significantiy to public understanding of the operations or activities of the government and is not prinarily In the commercial interest of the requester.

From: Robfes*Alcaw lesse To: Elliott Bobat Cc: JbOfIJas Eric SUbject: FW: ACITON: FOIA NRC-201 8 ~

• estlmall! clue 1/30/18 Date: Wednesday, January 24, 2018 3:31:00 PM Importance: High FYI. Somebody FOIA'd the End of Cycle Note.

From: Kauffman, Lisa Sent: Wednesday, January 24, 2018 3:28 PM To: Jones, Heather <HeatherJones@nrc.goV>

Cc: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nrc.gov>; Thomas, Eric <Eric.Thomas@nrc.goV>

Subject:

ACTION: FOIA NRC-2018-000304 - estimate due 1/30/18 Importance: High Hi Heather, A FOIA came in requesting ML18019A140. At this time I only need an estimate for how long it would take staff to review the record for FOIA release. The estimate is due back to me by January 30th.

Below is the link to the document in ADAMS:

View ADAMS Properties MLl 8019AI40 Open ADAMS Document (EOC OE Note-2018)

Thanks, Lisa Li.,s.a., K~~ FOIA Cc-or~

Reactor Information Services Branch Division of Mission and Program Support Office of Nuclear Reactor Regulation 301-415-8199 / Usa.Kauffman@nrc gov From: Chidichlmo, GabrJele Sent: Wednesday, January 24, 2018 2:45 PM To: RidsNrrMailCenter Resource <RjdsNrrMa jlCenter.Rr ur e1a1nrc,eoy>

Cc: Kauffman, Lisa <Lisa.Kauffman@nrqov>

Subject:

FW: FOIA Assignment for NRC-2018-000304- please provide fee estimate for non excepted requester by 1/30/18

Dear Lisa,

no incoming attached since the requester submitted this FOIA electronically.

We just tasked in Foia Online.

The ML was created by NRR and is non public Thanks

r - - - - - -- - - - - - - - - - - - - -- - - - - - - -- - -

Gaby From: toia@rcgu!atioos.gov [1]

Sent: Wednesday, January 24, 2018 10:53 AM To: Chidichimo, Gabriele <Gabrje!e.Chjdjchimp@nrc.gov>

Subject:

[External_Sender] FOIA Assignment for NRC-2018-000304 You have been assigned to the FOIA request NRC-2018-000304. Additional details for this request are as follows:

• Assigned By: Stephanie Blaney

• Request Tracking Number: NRC-2018-000304

• Due Date: N/ A

• Requester: Paul M. Blanch

• Request Track: Simple

• Short

Description:

N/A

• Long

Description:

ML18019A140, EOC OE Note-2018.

Robles-Alcaraz, Jesse From: Robles-Alcaraz, Jesse Sent: Thursday, January 25, 2018 9:43 AM To: Elliott, Robert Cc: Thomas, Eric

Subject:

RE: ACTION by 1/30: FOIA NRC-2018-000304 l(b) 5)

Got it.

From: Elliott, Robert Sent: Thursday, January 25, 2018 9:41 AM To: Robles-Alcaraz, Jesse <Jesse.Robles-Alc.araz@nrc.gov>

Cc: Thomas, Eric <Eric.Thomas@nrc.gov>

Subject:

ACTION by 1/30: FOIA NRC-2018-000304

Jesse, Can you take the lead on this one for the branch?

Thanks!

Rob From: Jones, Heather Sent: Thursday, January 25, 2018 8:58 AM To: Elliott, Robert <Robert.Elliott@nrc.gov>

Cc: Thomas, Eric <Eric.Thomas @nrc.gov>

Subject:

ACTION by 1/30: FOIA NRC-2018-000304 Importance: High

Rob, Please see the FOIA below and respond to Lisa.

Thanks!

Heather From: Kauffman, Lisa Sent: Wednesday, January 24, 2018 3:28 PM To: Jones, Heather <Heather.Jones@nrc.gov>

Cc: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz @nrc.gov>; Thomas, Eric <Eric.Thomas@nrc.gov>

Subject:

ACTION : FOIA NRC-2018-000304 - estimate due 1/30/18 Importance: High Hi Heather, A FOIA came in requesting ML18019A140. At this time I only need an estimate for how long it would take staff to review the record for FOIA release. The estimate is due back to me by January 30th.

Below is the link to the document in ADAMS:

View ADAMS Properties ML18019A140 Open ADAMS Document (EOC OE Note-2018 )

Thanks, Lisa L~ ~ ' FOtA c.ccr~

Reactor Information Services Branch Division of Mission and Program Support Office of Nuclear Reactor Regulation 301 -415-8199 / Lisa.Kauffman@nrc.gov From: Chidichlmo, Gabriele Sent: Wednesday, January 24, 2018 2:45 PM To: RidsNrrMailCenter Resource <RidsNrrMailCenter.Resource @nrc.gov>

Cc: Kauffman, Lisa <Lisa.Ka uffrnan @nrc.gov>

Subject:

FW: FOIA Assignment for NRC-2018-000304- please provide fee estimate for non excepted requester by 1/30/18

Dear Li sa,

no incoming attached since the requester submitted this FO IA electronically We just tasked In Foia On line.

The ML was created by NRR and is non public Thanks Gaby From: foia@regulations.gov (mai lto :foia@regulations.gov)

Sent: Wednesday, January 24, 2018 10:53 AM To: Chidichimo, Gabriele <Gabriele.Chld lchirno @nrc.gov>

Subject:

(External_Sender) FOIA Assignment for NRC-2018-000304 You have been assigned to the FOlA request NRC-2018-000304. Addhional details for this request are as follows:

• Assigned By: Stephanie Blaney

• Request Tracking Number: NRC-2018-000304

• Due Date: NIA

• Requester: Paul M. Blanch

• Request Track: Simple *

• Short

Description:

NIA

• Long

Description:

ML18019AJ40, EOC OE Note-2018.

2

From: RQbles*Alr.acaz Jesse To: Thompson John; Sjgmoo Rebecca* O,meaJ. Jason- Piloolfc Stephen Cc: Thomas Erjc

Subject:

FW: AcnON by 1/30: FOIA NRC-2018-000304 Date: Thursday, Janual)' 25, 2018 9:47:00 AM Hi,

Thanks, Jesse From: Elliott, Robert Sent: Th ursday, January 25, 2018 9:41 AM To: Ro bles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nrc.ga11>

Cc: Thomas, Eric <Eric.Thomas@nrc.goV>

Subject:

ACTION by 1/30: FOIA NRC-2018-000304

Jesse, Can you take the lead on this one for the branch?

Thanks!

Rob From: Jones, Heather Sent: Thursday, January 25, 2018 8:58 AM To: Elliott, Robert <Robert Elliott@nrqov>

Cc: Thomas, Eric <t.rlc,Thomas@nrc gov>

Subject:

ACTION by 1/30: FOIA NRC-2018-000304 Importance: High

Rob, Please see the FOIA below and respond to Lisa.

Thanks!

Heather From: Kauffman, Lisa Sent: Wednesday, January 24, 2018 3:28 PM To: Jones, Heather <HeaLher Jones@nrc gov>

Cc: Robles-Alcaraz, Jesse <Jesse Robfes-A!caraz@nrc,goV>; Thomas, Eric <Eric Thomas@nrc eov>

Subject:

ACTION : FOIA NRC-2018-000304 - estimate due 1/30/18

Importance: High Hi Heather, A FOIA came in requesting Ml 18019A140. At this time I only need an estimate for how long it would take staff to review the record for FOIA release. T he estimate is due back to me by January 30th.

Below is the link to the document in ADAMS :

Yiew ADAMS Properties ML18019Al4Q Open ADAMS Docwnent (EOC OE Note--2018)

Thanks, Lisa Li.M,., ~ FOIA C c c r ~

Reactor Information Services Branch Division of Mission and Program Support Office of Nuclear Reactor Regulation 301-415-8199 / usa.Kauffman@nrc.gov From: Chidichimo, Gabriele Sent: Wednesday, January 24, 2018 2:45 PM To: RidsNrrMailCenter Resource <Rjdsf\JccMailCenter Resource@nrc goy>

Cc: Kauffman, Lisa <Usa.Kauffman@nrc gov>

Subject:

FW: FOIA Assignment for NRC-2018-000304- please provide fee estimate for non excepted requester by 1/30/18

Dear Lisa ,

no incoming attached since the requester submitted this FOIA electronically We just tasked in Foia Online.

The ML was created by NRR and is non public Thanks Gaby From: foia@reeu lat1ons gov [mailto*foja@ce&iulatioos gov]

Sent: Wednesday, January 24, 2018 10:53 AM To: Chidichimo, Gabriele <Gabriele Cbidicbiroo@nrc.gOV>

Subject:

[External_Sender] FOIA Assignment for NRC-2018-000304 You have been assigned to the FOIA request NRC-20 18-000304. Additional details for this request are as follows:

• Assigned By: Stephanie Blaney

• Request Tracking Number: NRC-2018-000304

• Due Date: N/A

• Requester: Paul M. Blanch

• Request Track: Simple

• Short

Description:

N/A

• Long

Description:

ML18019A140, EOC OE Note-2018.

Robles-Alcaraz, Jesse From: Robles-Alcaraz, Jesse Sent: Monday, January 29, 2018 12:24 PM To: Thomas, Eric

Subject:

Fw: REMINDER: ACTION: FOIA NRC-2018-000304 - estimate due 1/30/18 Importance: High (b)(5)

From: Jones, Heather Sent: Monday, January 29, 2018 9:58 AM To: Thomas, Eric; Robles-Alcaraz, Jesse Cc: Elliott, Robert

Subject:

REMINDER: ACTION : FOIA NRC-2018-000304 - estimate due 1/30/18 FYI From: Kauffman, Lisa Sent: Monday, January 29, 2018 9:56 AM To: Jones, Heather <HeatherJones@nrc.gov>

Subject:

FW: ACTION: FOIA NRC-2018-000304 - estimate due 1/30/18 Importance: High Good Morning, Just a reminder that this estimate is due tomorrow.

Thanks!

From: Kauffman, Lisa Sent: Wednesday, January 24, 2018 3:28 PM To: Jones, Heather <Heather.Jones@nrc.gov>

Cc: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nrc.gov>; Thomas, Eric <Eric.Thomas@nrc.gov>

Subject:

ACTION: FOIA NRC-2018-000304 - estimate due 1/30/18 Importance: High Hi Heather,

A FOIA came in requesting Ml 18019A140. At this time I only need an estimate for how long it would take staff to review the record for FOIA release. The estimate is due back to me by J~n~ary ~0th.

Below is the link to the document in ADAMS:

View ADAMS Properties ML18019A140 Open ADAMS Document (EOC OE Note-2018)

Thanks, Lisa l-iMl-' ~ FOIA c.ccr~

Reactor Information Services Branch Division of Mission and Program Support Office of Nuclear Reactor Regulation 301-415-8199 / Usa.Kauffman@nrc.gov From: Chidichlmo, Gabriele Sent: Wednesday, January 24, 2018 2:45 PM To: RidsNrrMailCenter Resource <RidsNrrMailCenter. Resource@ nrc.gov>

Cc: Kauffman, Lisa <Lisa.Kauffman @nrc.gov>

Subject:

FW: FOIA Assignment for NRC-2018-000304- please provide fee estimate for non excepted requester by 1/30/18

Dear Lisa,

no incoming attached since the requester submitted this FOIA electronically .

We just tasked in Foia Online.

The ML was created by NRR and is non public Thanks Gaby From: foia@regulations.gov [2]

Sent: Wednesday, January 24, 2018 10:53 AM To: Chidichimo, Gabriele <Gabriele.Chidichimo@nrc.gov>

Subject:

[External_Sender] FOIA Assignment for NRC-2018-000304 You have been assigned to the FOIA request NRC-2018-000304. Additional details for this request are as follows :

• Assigned By: Stephanie Blaney

• Request Tracking Number: NRC-2018-000304

• Due Date: N/A

• Requester: Paul M. Blanch

• Request Track: Simple

• Short

Description:

N/A

• Long Description : ML18019A140, EOC OE Note-2018.

2

Ennis, Tina From: Chidichimo, Gabriele Sent: Tuesday, January 30, 2018 11:24 AM To: Kauffman, Lisa Cc: RidsNrrMailCenter Resource

Subject:

RE: FOIA Assignment for NRC-2018-000304, please provide responsive records by 2/13/18 Thank you Lisa, we also just tasked via FOIA online.

We are unable to provide a copy of the incoming request since this requester provided his info via FOIA online Please let us know if you have any questions and thank you or your help Gaby From: Kauffman, Lisa Sent: Tuesday, January 30, 2018 9:37 AM To: Chidichimo, Gabriele <Gabriele.Chidichimo@nrc.gov>

Subject:

RE: FOIA Assignment for Fee Estimate for Request NRC-2018-000304 Hi Gaby, The estimate for this FOIA is :

Search time : 1 m inute Review time : 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Pages : 8

Thanks, Li.,s,o.., ~~ FOIA C c o r ~

Reactor Information Services Branch Division of Mission and Program Support Office of Nuclear Reactor Regulation 301-415-8199 / FOIA CAC: ZFOOOO From: foia@regulations.gov [mailto:foia @regulations.gov)

Sent: Wednesday, January 24, 2018 2:41 PM To: RidsNrrMailCenter Resource <RidsNrrMailCenter.Resource @nrc.gov>

Subject:

[External_Sender] FOIA Assignment for Fee Estimate for Request NRC-2018-000304 Your office has been assigned FOIA request task

• Fee Estimate. Additional details for this item are as follows:

• Tracking Number: NRC-2018-000304

• Requester: Paul M. Blanch

• Request Track: Simple

• Assigned By: Gabriele Chidichimo

• Submitted Date: 01 /24/2018

• Due Date: 01 /30/2018 1

Description:

please provide a fee estimate for non excepted requester since the requester submitted his reque t online, we are unable to send you the incoming request. the ML number he is seeking is non publicly available and was created by NRR. Thank you for your help Gaby 2

Robles-Alcaraz, Jesse From: Robles-Alcaraz, Jesse Sent: Monday, February 12, 2018 9:00 AM To: Kauffman, Lisa Cc: Thomas, Eric

Subject:

RE: ACTION: FOIA NRC-2018-000304 - Record due on 2/31/18 Hi Lisa, I'll be sure you get our input by tomorrow Thanks, Jesse From: Kauffman, Lisa Sent: Monday, February 12, 2018 8:58 AM To: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nrc.goV>

Cc: Thomas, Eric <Eric.Thomas@nrc.gov>

Subject:

FW: ACTION: FOIA NRC-2018-000304 - Record due on 2/31/18 Importance: High Just a reminder that redacted records are due tomorrow

Thanks, Lisa From: Kauffman, Lisa Sent: Tuesday, January 30, 2018 11:37 AM To: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz @nrc.goV>; Jones, Heather <Heather.Jones@nrc.gov>

Cc: Thomas, Eric <Erlc.Thomas @nrc.gov>

Subject:

ACTION: FOIA NRC-2018-000304

• Record due on 2/31/18 Importance: High Thanks Jesse ,

Per the assignment below, you may resume the search . The due date to provide the redacted record to me is February 13111

• You can do redactions on paper using post its (do not write on the document itself except to mark areas in pencil), or you can do electronic marking in Adobe I have attached the FOIA exemptions that you may use in your review. If using exemption 5 or 7F, you must also provide a harm statement.

Let me know if you have any questions.

Your office has been assigned FOIA request task - Other. Additional details for this item are as follows:

• Tracking Number: NRC-2018-000304

• Requester: Paul M. Blanch

• Request Track: Simple

• Assigned By: Gabriele Chidichimo

• Submitted Date: 01/30/2018

,* Due Date: 02/13/2018

Description:

please resume search

Thanks, LiMv K ~ , FOIA C o o r ~

Reactor Information Services Branch Division of Mission and Program Support Office of Nuclear Reactor Regulation 301-415-8199 / FOIA CAC : ZFOOOO From: Robles-Alcaraz, Jesse Sent: Tuesday, January 30, 2018 9:29 AM To: Kauffman, Lisa <Lisa.Kauffman@nrc.gov>; Jones, Heather <Heather.Jones@nrc.gov>

Cc: Thomas, Eric< ric.Thom s@nrc.gov>

Subject:

RE: ACTION: FOIA NRC-2018-000304 - estimate due 1/30/18

Lisa, The document contains some information that needs to be redacted . I estimate the review to take about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Thanks, Jesse E. Robles U.S. Nuclear Regulatory Commission Reactor Systems Engineer NRR/DIRS/IOEB 301 -4 15-2940 301-415-3061 (fax)

Jesse.Roble.s@!,rc.gov From: Kauffman, Lisa Sent: Wednesday, January 24, 2018 3:28 PM To: Jones, Heather <Heather.Jones @nrc.gov>

Cc: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nrc.gov>; Thomas, Eric <Eric.Thomas@nrc.gov>

Subject:

ACTION : FOIA NRC-2018-000304 - estimate due 1/30/18 Importance: High Hi Heather, A FOIA came in requesting ML18019A140. At this time I only need an estimate for how long it would take staff to review the record for FOIA release. The estimate is due back to me by January 30th.

Below is the link to the document in ADAMS:

2

View ADAMS Properties ML18019A140 Open ADAMS Document ( OC OE Note-2018)

Thanks, Lisa LiM-- K ~ , FOIA C c o r ~

Reactor Information Services Branch Division of Mission and Program Support Office of Nuclear Reactor Regulation 301-415-8199 / Llsa.Kauffman@nrc.gov From: Chidichimo, Gabriele Sent: Wednesday, January 24, 2018 2:45 PM To: RidsNrrMailCenter Resource <RidsNrrMailCenter.Resource@nrc.gov>

Cc: Kauffman, Lisa <Lisa.Kauffman @nrc.gov>

Subject:

FW: FOIA Assignment for NRC-2018-000304- please provide fee estimate for non excepted requester by 1/30/18

Dear Lisa ,

no incoming attached since the requester submitted this FOIA electronically We just tasked in Foia Online.

The ML was created by NRR and is non public Thanks Gaby From: fola@regulations.gov [3]

Sent: Wednesday, January 24, 2018 10:53 AM To: Chidichimo, Gabriele <Gabrlele.Chidichimo@nrc.gov>

Subject:

[Extemal_Sender] FOIA Assignment for NRC-2018-000304 You have been assigned to the FOIA request NRC-2018-000304. Additional details for this request are as follows:

• Assigned By: Stephanie Blaney

• Request Tracking Number: NRC-2018-000304

• Due Date: N/A

• Requester: Paul M. Blanch

• Request Track: Simple

• Short

Description:

NIA

• Long

Description:

ML18019A140, EOC OE Note-2018.

3

Robles-Alcaraz, Jesse From: Robles-Alcaraz, Jesse Sent: Tuesday, February 13, 2018 8:24 AM To: Thompson, John

Subject:

RE: FOIA NRC- 2018-000304 Attachments: EOC_proposed redactions.pdf

.Ib) 5)

Here is an updated version wit1....___________.

From: Thompson, John Sent: Tuesday, February 13, 2018 8:22 AM To: Robles-Alcaraz, Jesse <Jesse.Robles-Alcaraz@nrc.gov>

Subject:

RE: FOIA NRC-2018-000304 ok From: Robles-Alcaraz, Jesse Sent: Tuesday, February 13, 2018 8:11 AM To: Sigmon, Rebecca <Rebecca .Sigmon@nrc.gov>; Thompson, John <John.Thompson@nrc.gov>; Carneal, Jason

<Jason.Carneal@nrc.gov>; Blusius, Brian <Brian.Blusius@nrc.gov>

Subject:

FOIA NRC-2018--000304

Thanks, Jesse E. Robles U.S. Nuclear Regulatory Commission Reactor Systems Engineer NRR/DIRS/IOEB 301-415-2940 301-415-3061 (fax)

Jesse.Robles@nrc.gov

I)ll1ll~'I, DO NOT FORWARD ANY EXCERPTS OUTSIDE OF NRC WITHOUT FIRST OBTAINING PERMISSION FROM ORIGINATOR Operating hnerience Nole January 2018 b)(5)

(b)(5) b)(5)

(b)(5)

(b) 5)

b)(5)

(b)(5}

From : Kauffman Ltsa To: Chjdjchtmo Gabriele Subjett: RE: FOIA NRC-2018-000304 NRR Response O.te: Thursday, February 15, 2018 12:33:20 PM Hi Gaby, (b)(5)

Thanks, Lisa From: Chidichimo, Gabriele Sent: Thursday, February 15, 2018 11:19 AM To: Kauffman, Lisa <Lisa.Kauffman@n rc.goV>

Subject:

FW: FOIA NRC-2018-000304 NRR Response Importance: High Sorry for the confusion Lisa Please see attachment:

This NRC letter (not on official letterhead lists the ML numbers above th (b)(5) lhank you Gaby From: Kauffman, Lisa Sent: Tuesday, February 13, 2018 2:59 PM To: Chidlchimo, Gabriele <Gabriele Chidichimo@nrc gay>

Subject:

FW: FOIA NRC-2018-000304 NRR Response Importance: High Hi Gaby, See NRR's response to this FOIA below.

Let me know if you need anything else.

Thanks, Lisa

From: Robles-Alcaraz, Jesse Sent: Tuesday, February 13, 2018 12:49 PM To: Kauffman, Lisa <Lisa Kauffman@arc.gov>

Cc: Thomas, Eric <Ede Jhomas@nrc gov>

Subject:

RE: ACTION: FOIA NRC-2018-000304 - Record due on 2/13/18

Lisa, 5

Attached is the redacted documend b l

Thanks, Jesse

April 19,2014 Mr. George I. Hutcherson, Director Suppliers and New Plant Deployment Institute of Nuclear Power Operations Suite 100 700 Galleria Parkway, SE Atlanta, GA 30339-5943

Dear Mr. Hutcherson:

I am responding to your letter, dated February 5, 2014, which enclosed an affidavit from the Institute of Nuclear Power Operations (INPO} related to documents INPO voluntarily submits to the United States Nuciear Regulatory Commission (NRC). The NRC understands that the purpose of INPO submitting the affidavit is to ensure the NRC will protect from public disclosure INPO's trade secrets and its confidential and proprietary documents that are voluntarily submitted to the NRC.

The NRC reviewed the enclosed affidavit and finds it acceptable. The NRC acceptance is based, in part, on the understanding that INPO will be including "Proprietary" markings on each page of submitted documents containing trade secrets or other proprietary or confidential information rather than relying exclusively on other markings such as "General Distribution,*

"Limited Distribution" and/or "Restricted Distribution" as it has in the past.

In addition, the NRC assures INPO that the adoption of this new INPO marking practice for documents submitted to the NRC from this point forward does not change how the NRC intends to handle and protect previous INPO document submissio~s that were not marked as "Proprietary." Consistent with previous understandings between the NRC and INPO, the NRC will continue to treat as proprietary, and accord appropriate protections to, previously submitted INPO documents that INPO identified as containing trade secrets or other proprietary or confidential information, but did not explicitly mark as "Proprietary."

The affidavit will be distributed as necessary to any NRC office or NRC personnel that may come into contact with INPO documents and information to assure the protection of INPO's trade secrets and Its confidential and proprietary information.

G. Hutcherson If you have any questions regarding this letter, please contact Mr. F. Paul Peduzzi, Executive Technical Assistant, Office of the Executive Director for Operations at (301) 415-1167 or by email at francis.peduzzi @nrc.gov.

Sincerely, IRA/

Michael R. Johnson Deputy Executive Director for Reactor and Preparedness Programs Office of the Executive Director for Operations

G. Hutcherson If you have any questions regarding this letter, please contact Mr. F. Paul Peduzzi, Executive Technical Assistant, Office of the Executive Director for Operations at (301) 415-1167 or by email at francis .peduzzi@nrc.gov.

Sincerely, IRA/

Michael R. Johnson Deputy Executive Director for Reactor and Preparedness Programs Office of the Executive Director for Operations DISTRIBUTION: OED0-14-00152 EDO r/f OGC ADAMS ACC ESSION NO: PkCQ : ML14072A230 , Incomn11: ML14072A233 Memo: ML14105A473 *v1aema II I

OFFICE OEDO/TCCM OEDOfTCCM OGC OEDO/DEDR NAME F. Peduzzi K. Brock J. Adler* M. Johnson DATE 04/16 /14 04/16/14 04/18/14 04/19/14 OFFICIAL RECORD COPY

BEFORE TIIE U.S. NUCLEAR REGULATORY COMMISSION AFFIDAVIT OF 11IB INSTITlITE OF NUCLEAR POWER OPERATIONS PURSUANT TO 10 C.F.R. § 2.390 PER.SONALLY APPEARED BEFORE ME, the undersigned officer duly authorized by law to administer oaths, RONN SMITH, who after being sworn stated of his personal knowledge as follows:

1. I am the Director of Communications for the Institute of Nuclear Power Operations

("INPO") in Atlanta, Georgia I have held this position continuously since July 2007 and previous to that I was a section manager in Communications. In addition, I was the Manager of Corporate Communications at.Wolf Creek from February 1986 through October 1994. In all, I have nearly thirty years of personal experience in the commercial nuclear power industry.

2. As Director of Communications for INPO, I have been specifically delegated by the Chief Executive Officer ofINPO the function of protecting INPO's confidential and proprietary information and reports from public discloSlll'C. I have similarly been specifically delegated the responsibility of designing and implementing procedures for ensuring that INPO's confidential and proprietary information and reports are held in confidence by INPO. Finally, I am authoriz.ed by INPO to apply on its behalf for confidential treatment of its confidential and proprietary information and reports under 10 C.F.R. § 2.390.

3. The information and reports that INPO voluntarily submits to the U.S. Nuclear Regulatory Commission (the "NRC") include INPO Operating Experience products, 1

INPO Event Reports (IERs); other INPO documents and reports; and information in the INPO Consolidated Events (ICES) Da1abase (collectively, "Confidential INPO Documents).

4. The Confidential INPO Documents include trade secrets and are confidential commercial information that INPO does not customarily make available to the public, are held in confidence by lNPO, are submitted voluntarily by INPO to the NRC, are not available in public sources, and whose disclosure would cause substantial harm to lNPO's competitive position. INPO voluntarily submits the Confidential INPO Documents to the NRC in confidence, and with the expectation and understanding that they will be maintained as confidential.

5. The Confidential INPO Documents other than the ICES database are marked with one of four distribution categories: "Open Distribution," "General Distribution," "Limited Distribution," or Restricted Distribution." Documents designated as "Open Distribution" contain no INPO proprietary information and arc available for release to the general public. Documents marked as "General Distnoution," "Limited Distribution," or "Restricted Distribution" contain trade secrets or other confidential and proprietary information that INPO does not customarily release to the public and maintains in confidence. The ICES database is marked "Proprietary Commercial Information," or "ICES Proprietary Information," and also contains trade secrets or other information that INPO does not release to the public and maintains in confidence. The NRC should not release to the public any Confidential INPO Documents marked as "General Distribution," "Limited Distnoution," or Restricted Distribution," or any data from the ICES database.

2

6. INPO also voluntarily submits to the NRC Performance Indicator data. including certain data that are trade secrets and/or are confidential commercial information, which INPO does not customarily release to the public, are held in confidence by INPO, are not available in public sources, and whose disclosure would cause substantial harm to INPO's competitive position. INPO voluntarily submits the confidential Performance Indicator data to the NRC in confidence, and with the expectation and understanding that it will be maintained as confidential. Toe file name of each file in the Performance Indicator data that contains trade secrets or is otherwise confidential contains the word "proprietary." The NRC should not release to tho public any information in the Performance Indicator data that is contained in a file with the word "Proprietary" in the filename.

7. The public disclosure of any of the documents, information, reports, and data described above would cause substantial harm to the competitive position of INPO, taking into account the fact that it would be extremely difficult to obtain the same information elsewhere, and considering the amount of effort and resources expended by INPO in developing such materials.

SUBSCRIBED & SWORN TO BEFORE ME TlilS ~DAY OF FEBRUARY 2014

~~

3

b 5)

Ennis, Tina From: Paul < pmblanch@comcastnet>

Sent: Wednesday, February 21, 2018 2:36 PM To: Chidichimo, Gabriele Cc: Paul Blanch Subject [External_Sender] Re: status update NRC 2018 000304 Thanks for the update p

(bX6)

On Feb 21 , 2018, at 1:56 PM, Chidichimo, Gabriele <Gabricle.Chidichimo@mc. g.ov> wrote:

Good afternoon Mr. Blanch, We are pleased lo inform you that your FOIA request has been processed and is presently undergoing legal review.

The requested records will be provided to you in the near future Thank you, Gaby Gabriele Chidichimo Government Information Specialist OCIO-FOIA USNRC Tel: 301-415-6968 Mailbox stop TWFN-2-F43 Gabriele.Chidichimo c. nrc.f.QY 1

..... - - **--_. -- ---- --* -* -~*-*------

NRC POIIII

~7\

,...~

Pan I 1

U.&. NUCU!IJt ltaGUlATOltY C'O .... aoN RESPONSE TO FREEDOM OF FOIA I 2018-000304 11 RUPONIE NUIIBER I

I

~ .....r; INFOR TION ACT (FOIA) REQUEST REIPONaE TYPE D IN1DIIII ~ F1IW.

ltEQUU1'ER: DATI!:

!Paul Blanch DDCltlP110N OF REQUESTED RECORDS:

11 21231201 s I IML18019Al40, EOC OE Note-2018. Final response publicly available at ML18057A007 PART I, - INFORMATION RELEASED You hlMI the right to seek ... il1ance from the NRC'1 FOIA Public: Uabon. Contact WTformatlon for the NRC'I FOIA Public Ualaon 18 avalable at btlpa'.ltwww nee galllDlldi~iilcQotai;t-fl2ia blml D lqeney ntCOrds IUbjec:t lo the request ire already available on the Public NRC Website, NRC Public Doc:ument Room.

i, Public ADAMS or on microfiche in the

~ Agency IIICOl'da sU)ject ID Iha r&QUeSt are endosed.

Records subject to the ntquest that contain information originated by or of ini.r.st to .-iottier Federal agency haw been D refened to that agency (see comments sectiOn) for a disclosure detennlnation and direct response to you.

D We are continuing to process your request. .

~ See Comments.

PART I.A - FEES tiQEg§ AMOUNr D You wll be billed by NRC for tl9 amount hwd.

~ Minimim flle threshold not met II $0.00 II D You wil receiw a refund for the amount ilted. D Due to our duyec:1 response, you wil

'SNC'am-*lrlr. .

D Fees wahled. net be charged fNs.

PART 1.8 - INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE We did not locate ~ n c y records responsi\4e to your ~st. Note: Agencies may lrHt three discrelll c:at.gories cA law D notillcation enfoo:ement and given to aeauty records as not tubject to requesters; l shoukl not FOIA rexdulionaj. 5 u.s.c. 552(c;). This is a standa!d be taken to mean that any exckJded recorda do, or do not. exist.

~ We have withheld certain Information pursuant to the FOIA exemptions desctibed, and for the reasons stated, in Part II.

D Because this is an interim response to your request you may not appeal at this tine. We wi notify you of your right to appeal any of the rnponses we have issued in response to your 1"8Quest When we issue our final determination.

You m a ~ I this final determination within 90 calendar days of the dalie of this responseJI sending a letter or e-mail to the FOIA O r, at U.S. Nuclear Regulatory Commission, Washl~ton. D.C. 20555-0001 , or f Resou~nrc gov Please be 0 sure to lnc;.lucle on yiour lebr or email that it is a "FOIA Appeal You have the right to IMk dispute Nl50lution services tom the NRC's Public; U.19on, or the Offic:e of Gov9mment Information Services (OGIS). Contac;t information for OGIS II avalable at Nlpl*t u 1a:bm gg~tabouk>aillcontact41fll!mltiD.O btm PART l,C COMIENTS I Uh attached Comments continuation page If reaulrecO Please note:

The requested record is being released in part a ........

• Fl'Nllorn of I Act Offlcar or o.a- Dlltrtbueloft

~\ \) 0~~\'1 D\~Y'IUJ I

181 llmR I OFFICE ACTION OFFICER F~OFFICER ooc

~ PUBLIC ADAMS NAME GChldlchnO h ~, Ct.c~

DATE 02121/I011 ~ \ ~ I f6 )../i,/J~ D NON-PUBLIC ADAMS NRC Form *l:{;X~rsvilj ' I ....,.1on I

........ - * -* ~ - .. l .. --r~--* . . . ,. ,. . ..__..__,.._ . . . . . *-.. .,...- . . . . . . . . . . .*--~---,.-...~. . ..,.,. . .. . . . . . . _. . .,...-... - ... . .

NRC FORM '64 Part II U.S. NUCLEAR REGULATORY COIIIIISSION FOIA/PA (1)8.:1()13) , . . . ~

NRC 2018 000304 RESPONSE TO FREEDOM OF INFOR¥ATION

(~, DATE

~ ..... ~ ACT (FOIA) / PRIVACY ACT (PA) REQUEST 2/23/2018 PART II.A - APPLICABLE EXEMPTIONS rD I Records subject to the 111quest th1t e111 contllned In ltle specified group 1111 being withheld In their entirety or in part under the Exemption No.(&) of the PA and/or the FOIA II Indicated beloW (5 U.6.C. 5521 and/or 5 U.S.C. 562(b)).

Exemption 1: The withheld Information Is proper1y clnsHled pursuant ID Exeaitllle Onler 12958.

D Exemption 2: The wtlhhekl lnfonneuon ralales solely to 1he lnlemal peraonnel rules Md practices of NRC.

D Exemption 3: The withheld Information Is specl1lcllly ewempted from public disdosura by allltute lndlcated.

D Sections 141-145 of the Atomic Energy Act, whldl prohibits the dlaclosur* of Restricted Data or Fonnerty Restricted Dita (42 U.S.C.

2161-2165). .

D Secllon 147 of the Atomic Energy Act. whieh prohl>ltl 1ht dlsdolu111 of UndHa~ Safeguards lnformdon (42 U.S.C. 2167).

D 41 U.S.C., Section 4702(b), prohlblla the dlldoaure of contractor proposals In the possession and control of an exec:ufve egency to any peraon under aection 552 ofTl11e a. u.s.c. (1he FOIA), except when inc:orporated Into the contract belween the agency and Ille IUbmllter of the propo111.

[{I Exemption 4: The wllhheld Information II a nde secret or commercill or lln1nc:lal lnformafion that is beinO wtthheld for the r111on(1) Indicated.

[{] The Information la consldered to be con1ide11tlll bu1l114111 (proprietary) Information.

D The Information la considered to be propnetary becauae It concerns a lloensee's or 1ppllclnt1 physical proteCllon or materlat control and accounting program for 1pecial nuclear m11111fal pursuant to 10 CFR 2.390(d)(1).

0 B The lnlonnallon wet slbl'lltted by I foreign SOUl"CI and received In conldenoe pursuant to 10 CFR 2.390(d)(2).

Di*closure wltt hann an Identifiable private or gOll9ffll"n&fltat Interest.

Exemption 5: The withheld lnfonnatlon conalata ol lnteragency or lntniageney rlCOlds that ere not 1M1llble through clacovery dumg llllgation.

Applicable privtleges:

Dellberlllve process: Dladoaure of predeclslonal Information would tend to Inhibit the open and frank excllange c:A Ideas e11entilll to the 0 deiberatlvll proceaa. VVhere reoords are withheld In their entirety, the facts are Inextricably lnterlwlned wtll the predec:I lonal Information.

There also ,ra no reasonably segregable factual portion* because the releaae of the flcta woukl permit an Indirect Inquiry Into the prededslonal prooeu of the agency.

D Atlomey work-product privilege. (Dowments p r ~ by an attorney In contemplation of lillgltion)

D Attomey-dlenl prlvllege. (Confidential oomm1M11tatlons betwNn an attorney and hlllhlr client)

Exemption 6; Thi wllhllelcl Information Is exempted from public dladosure because Its disclosure wlll*1 result In a clearly unwarranted D invUion of personal prlwcy.

D Exempllon 7: The wl1hllelcl Information consists of recorda compiled for law enforcement purposet end I being withheld for the reaaon(a) Indicated.

(A) Disclosure ~ reasonably be expected to Interfere with an enforcement procNdlng (e.g., It would rew11 the acope, dlreellon. and D tocus of enforcement efforts, and thus could possibly alow recipients to take ldlon to &hlelcl potential wrong doing or 1 \'iotallon of NRC requirements from lnvestlgat-).

D (C) DISCIOSlft co~ constltule an unw1m1nted invasion of peraonal l)IIVacy.

(0) Thi Information conalsts of names of tndlvkti..11 and other lnformetion the dlldoaure of which QOUd r11sonabty be l>CPl(:led to reveal D ldel\tltiN ol confidential souroas.

D (E) Oisdoaun1 would reveal techniquea and procedulVI for law enforcement investi;atlona or proaecullons, or l)Uideilnes flat could n11son1bly be expected to risk circumvention of the law.

D DOTHER (F) Dllcloaun1 could reasonably be expected to endllllJOr the life or physical ..rety of en lndlYldual.

ISoeciM I

PART 11.B - DENYING OFFICIALS Pursuant to 10 CFR 9.25(g), 9.25(h), andtor 9.65(b) of the U.S. Nuclear Regulatory Commission regulations, It has been detennined that the Information withheld Is exel11)t from production or disclosure, and that Its production or disclosure is contrary to the public interest. The person responsible for the denial are those officiels Identified below as denying officials and the FOIA/PA Officer for any denials that may be appealed to the Executive Ditector for Operations (ED0).

APPEU.ATE OFFIQM.

DENYING OFFICIAL TITLE/OFFICE RECORDS DENIED !I)() eec:v IQ Stephanie Blaney FOJA/PA Officer X 0 D D LJ L LJ l I I I Appeal must be made in writing within 30 days of receipt of this response. Appeals should be meiled to the FOWPrivacy Act Offioer.

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, for action by the appropriate appellate official(s). You should clearly s ~ on the envelope and letter that it is a "FOIA/PA Appeal."

NRC FORM 464 Part II {~2013)

Robles-Alcaraz. Jesse From: Thompson, John Sent: Thursday, April 26, 2018 11:23 AM To: Robles-Alcaraz, Jesse

Subject:

FW: draft for OpE Note on RPS test boxes Attachments: FermiRPStestbox.dooc One more for EOC FOIA.

john From: Thompson, John Sent: Wednesday, June 28, 201711:37 AM To: Sigmon, Rebecca <Rebecca.Sigmon@nrc.gov>; Robles-Alcaraz, Jesse <.Jesse.Robles-Alcaraz@nrc.gov>

Subject:

draft for OpE Note on RPS test boxes Here is a draft of the RPS test box issue.

Feel free to comment (chop and dice).

{b)(5) john

Fermi i- Use of a RPS Test Box during Performance of Quarterly RPS Functional Channel Testing Results in the Inadvertent Loss of Two RPS Trip Functions.

In September of 2016, during at-power quarterly surveillance testing of the reactor protection system (RPS) instrumentation for the Main Steam Isolation Valves (MSIVs) and Turbine Stop Valves (TSV), the licensee inadvertently disabled two scram inputs associated with the Closure Functions for both MSIVs and TSVs.

More importantly, recently revised surveillance test procedures did not ensure that 3 out of the 4 steam lines closing in a trip remain available, as required by the plant's TS (See Fermi LER 2017-001 - 00 for additional information). This oversight was the result of a change in testing methodology via use of an "RPS test box.*

~WROG Recommendation 3Q The use of the RPS Test Box was a concept promoted by the Boiling Water Reactor Owner's Group (BWROG) in 2008 kcurren4 f.iersion is Recommendation 30, BWROG-TP-09-026, Revision 71). The goal was to reduce unnecessary RPS actuations and unplanned half scrams. According to the BWROG, the primary benefit of using the RPS test box is "the ability to test end of channel function during Channel Functional Tests white preventing a half scram from occurring. Use of this test box also allows some corrective work without further exposure to inadvertent half scrams for a single failure on a different channel. This reduces exposure to single failure on the opposite division."

The RPS test box typically consists of a 3-ohm resistor in parallel with a 2.5 VAC lamp terminated with banana jacks. Electrically, the RPS Test box is a low resistance path in parallel with the trip logic relay contacts. When the RPS test box is connected in parallel with channel input, the circuit will not be broken when the channel under test is actuated (trip aux relay drops out). The circuit will continue to pass current through the test box, keeping the scram contactors energized. The current will drop sufficient voltage across the resistor to illuminate the tamp, indicating the opening of relay contact under tes while not de-energizing (actuating) the scram contactors.

Aside from stating that users should review their licensin basis and other commitments to m nda ion 30 (b)( 4)

Use of a RPS test box was recognized by the licensee as a change in testing methodology that required a formal 50.59 evaluation. However, the licensee's 50.59 evaluation appears not to adequately address the implications of using the RPS test box given the complexities created

when bypassing multiple (parallel) relay contacts In conjunction with the additional TS Bases requirement to maintain operable 3 of 4 steam line signals. This lack of understanding and coordination by the licensee was a significant factor that resulted In the loss of the two scram functions and non-compliance with TS 3.3.1 .1. This error was introduced, in part, based on an apparent inadequate review resulting from a lack of appreciation of the complexities with bypassing parallel circuits and how these circuits interrelate to satisfy the TS operability requirements.

Offieial Use Only Sensitive lntemal lnfor:mation anEl PreElesisienal lnfonmtiOA Surrmary of Construction Experience (ConE)

Operating and construction experience was screened by the Operating Experience (OpE)

Center of Expertise (COE) staff throughout the assessment period. As a result, there was one proposed revision to Inspection procedure {IP) 41501, "ReviewofTralnlng and Qualification Programs" during the assessment period that has been accepted and is currently being sent out for regional review. A copy of the proposed revision was sent out separately to Mr. George Khouri. If needed, please contact Michael Webb for a status update.

When planning construction inspections for the next assessment period, the following noteworthy Operating and Construction experience issues should be cohsidered, as applicable:

1. Oil Sight Glass Issues (see first event in ML18019A140). Please review the inspector takeaways In this article. Related to IP 65001.06. "Inspection of ITAAC-Related lostaUatjon of Mechany l Components";

2.  !(b 4J and Contractor Oversight (see page 7 of ML 18019Al40).

Related to IP 65001.0B. Hlnspection of the ITAAC-Related Welding ProgramH;

3. NRC Access was granted to the construction experience module of the Institute o~

Nuclear Power Operations {INPO) Consolidated Events System (ICES) (see paRe 4 of M Ll 11223AS48l. l1bl(5) I (b)(5) I

4. Falsification of records by suppliers including CB&I Laurens, Le Creusot and Kobe Steel.

When planning for construction inspections, inspectors should be aware of the multiple exam les of record falsification roblems b multi le suppliers;

5. (b)(4)

Related to IP 65001.09, "Inspection of ITAAC-Related Installation of Electric and Fiber Optic Cable" :

6 . (b)(4)

7. EN 53167 - Duane Arnold- Insufficient design clearance to ground. This event covers the need to include sufficient design margin to account for dust accumulation and insect intrusion. For additional information, see INPO ICES Report 427646. Related to !f 65001.08. "Inspection of ITAAC-Related Installation of Electric Components and Systems" ;

8. lbaraki nuclear plant used erroneous fuel rod data for over 40 years. Related to IP 35007, "Quality Assurance Program Implementation During Construction and Pre-Construction Activities" and IP 65001 .8, "Inspection of the As-Built Attributes for Structures, Systems, and Components (SSCs) Associated with rr AAC";

Official Use ORiy Sensifr.*e Internal lnfermetien anEl PFOOeeisienal Information

Official Use Only SeAsiti':e IAteFRal IAfeFmatieA aAd PFeElec:isional Information (b)(4) 9.

(b)(4) to to IP 65001.08, "Inspection of ITAAC-Related Installation of Electric Components and Systems# ;

10. Point Beach Unit 1 LER 2017-003, "Degraded Condition" (see ML17347A773).

The rmst likely cause of the degraded barrier was crater cracking at a weld stop point in the root valve to instrument tubing welded joint. Related to IP 65001 .0B, "Inspection of the ITMC-Related Welding Program";

11 . LER 3972016002R01 - Colurmia Generating Station - Valve Closure Results In Momentary Increase In Secondaiy Containment Pressure (LER Supplement), is an illustration of a latent consequence of an i"l)roper electrical termination. Related to IP 65001 .09, "Inspection of ITMC-Related Installation of Electric and Fiber Optic Cable";

12. EN 52619 - EN - VOGTLE - Automatic Actuation Of Emergency Diesel Generator. The licensee determined the cause for the loss of the 1BA03 bus was that in the Open Phase panel, the cables for the trip signal and alarm signal were reversed . Related to IP 65001 .09, "Inspection of ITMC-Related Installation of Electric n F **

13 1b 4)

Official Use Only SeAsiti*,e IRtemal Information and Predec:isional lnformatioR