Text

FOIA/PA-2017-0698 - Agency Records Subject to the Request Are Enclosed
	ML18239A233
Person / Time
Site:	LaSalle
Issue date:	09/25/2017
From:	; NRC/OCIO
To:	;
References
	FOIA/PA-2017-0698
	Download: ML18239A233 (193)
	v • d • e

From: Pederson Cynthia To: lohnsoo Michael

Subject:

RE: Lasal le Date: Wednesday, J une 14, 2017 6:51:57 AM Not in agreement. Bill, McDermott, Darrell, O' brien and I will have a call Thursday morning. However, I do not expect we will align. Bill wants additional info that I do not think we can get in any reasonable time. Additionally, I will try to get ahold of Bill today for just the two of us to chat. May be challenging as we have Burns, Castel veter, etc. here today.

From: Johnson, Michael Sent: Wednesday, June 14, 2017 6:28 AM To: Dean, Bill <Bill.Dean@nrc.gov>; Pederson, Cynthia <Cynthia.Pederson@nrc.gov>

Subject:

Lasalle Sorry for bailing out early yesterday.

Where did we end up?

Mike

From: Kirkwood Sara To: Heck laced Su bj ect : RE: LaSalle TS 3.5.1 Da t e: Thursday, June 15, 2017 9:30:53 AM Thanks Jared. I'm finding the slides very helpful.

From: Heck, Ja red Sent: Thursday, Ju ne 15, 2017 10:29 AM To: Kirkwood, Sara <Sara.Kirkwood@ nrc.gov>

Subject:

LaSa lle TS 3.5.1

Sara, We are dealing with TS 3.5.1 Condition B.2.

Jared From: R3Scan@nrc.gov [1]

Sent: Thursday, Ju ne 15, 2017 9:31 AM To: Heck, Jared <Ja red.Heck@ nrc.gov>

Subject:

Attached Image

From: Ieffers. Mark To: Benjamin 1amie: Skokowski Richard

Subject:

RE: draft report - need comments by COB Tuesday 6/27 Date: Wednesday, J une 28, 201 7 10:37:56 AM Do we need to re-exit to discuss the URI?

From: Benj amin, Jam ie Sent: Wednesday, June 28, 2017 11:37 AM To: Jeffers, Mark <Mark.Jeffers@ nrc.gov>; Skokowski, Richard <Richa rd.Skokowski@nrc.gov>

Subject:

RE: draft re port - need comments by COB Tuesday 6/27 Yes, working it after hours.

No URI recommended Rick, what do I need to do to put together an enforcement panel package? What are the next steps.

If discretion is what we do for non-PD violations then I th ink we are done. I am ok with that.

No URI.

Anytime is good to talk.

From: Jeffers, Mark Sent: Wednesday, June 28, 2017 9:36 AM To: Benjamin, Jam ie <Jamje.Ben jamin@nrc.gov>

Subject:

RE: draft report - need comments by COB Tuesday 6/27

Jamie, I know you are busy with Point Beach, but we need to keep th is report moving. Some specific actions we need include:

Determine what we will be doing with the URI. Since we know the condition of the Unit 1 valve , do we still need an URI since we know that they all have the same design flaw as the violation?

Complete package for enforcement panel Determine if we are going to be consistent with previous non-PD violations and provide discretion Coordinate with EICS, determine next steps for enforcement panel.

Let me know when a good time to discuss would be.

Thanks, Mark

From : Benjamin, Jam ie Sent : Friday, Jun e 23, 2017 12:32 PM To: Rodriguez, Lionel <Lionel.Rodriguez@nrc.gov>; Farnan, Michael <Michael.Farnan@nrc.gov>;

Dunlop, Andrew <Andrew.Dunlop@nrc.gov>; Phi ll ips, Charles <Charles. Phi ll ips@nrc.gov>

Cc: Jeffers, Ma rk <Mark.Jeffers@nrc.gov>; Benjam in, Jam ie <Jamie.Benjamin@nrc.gov>

Subject:

draft report - need comments by COB Tuesday 6/27 Please review the report. Its draft and somewhat rough. Things may get modified a little based on what they find this weekend with 1E22-F004.

What do you like?

What don't you like?

What do you want added?

Thanks everyone.

Our team goal is to give this to Mark by COB next week.

Home stretch!

Jamie

From: Benjamin 1amie To: Skokowski Richard Cc: I effers Mark: Stoedter Karla

Subject:

2E22- F004 va lve Da te : Monday. June 19, 2017 12:43:44 PM (b)(S) Deliberative Privilege

From: Logaras Ha rral To: Wolf Carolyn Cc: Barker Allan; Heck !a[ed

Subject:

FW: LaSalle SIT Update Date: Tuesday, J une 06, 201 7 2:36:38 PM Carolyn, Please see Mark's message, below for additional detail on current pre-decisional deliberations.

Harral Logaras I Regional Government Liaison I Office of the Regional Administrator U.S. Nuclear Regulatory Commission Region-Ill I (630) 829-9659 I Ha rra l Logaras@nrc gov From: Jeffers, M ark Sent: Tuesday, June 06, 2017 2:34 PM To: Logara s, Harral <Harral.Logaras@nrc.gov>

Cc: Barker, Allan <Allan.Barker@nrc.gov>; Heck, Jared <Jared.Heck@ nrc. gov>; Benjamin, Jamie

<Jamie.Benjamin@nrc.gov>; Chandrathil, Prema <Prema.Chandrat hil@ nrc.gov>; Mit lyng, Viktoria

Subject:

RE: LaSalle SIT Update r- -----* l(b)(5 ) Deliberative Privileae I (b)(5) Deliberati ve Privilege Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Logaras, Harral Sent: Tuesday, June 06, 2017 1:02 PM To: Jeffers, Mark <M ark Jeffers@nrc.gov>

Cc: Barker, Allan <Allan.Barker@nrc.gov>; Heck, Jared <Jared .Heck@ nrq~ov>; Benj amin, Jamie

<Jamie.Benjamin@nrc.gov>; Chandrathil, Prema <Prema.Chandra thil@nrc.gov>; M it lyng, Viktoria

<Viktoria.M itlvog@nrc.gov>

Subject:

RE: LaSalle SIT Update Mark, Deliberative Privilege (b)(5) Deliberative Privilege Is that still where we are.

Harral Logaras I Regional Government Liaison I Office of the Regional Administrator U.S. Nuclear Regulatory Commission Region-Ill I (630) 829-9659 I Harral.Logaras@nrqiov

From : Jeffers, Ma rk Sent: Tuesday, June 06, 2017 8:03 AM To: Logaras, Harral <Harral.Logaras@nrc.gov>

Cc: Barker, Allan <Allan Barker@nrc.gov>; Heck, Jared <Jared.Heck@nrc.gov>; Benjamin, Jamie

<Jamie Benjamin@nrc gov>; Chandrathil, Prema <Prema Chandrathil@orc gov>; M itlyng, Viktoria

Subject:

RE: LaSalle SIT Update The only remaining inspection activities for the LaSalle SIT include inspecting the operability of the Unit 1 High Pressure Core Spray injection valve (i.e .* the opposite unit's valve to the one that failed). The team has gone back and forth with the licensee on the development of information that would provide reasonable assurance of operability. The licensee has continuously been updating their operability based on new information developed/provided by the BWROG, the valve vendor, specialty engineering firms, and an independent lab performing the failure analysis evaluation. The most recent delay was due to the delivery of the failure analysis report that was completed last Wednesday. The team is currently reviewing/inspecting the report and discussing the issues with the licensee. The team is scheduled to make their recommendation on the operability of the Unit 1 valve by Wednesday. Depending on the recommendation, we will then schedule the exit meeting . Please let me know if you have any questions.

Additionally, for your awareness, headquarters entered into the LIC-504 process (i.e. , risk informed decision making procedure developed after Davis Besse) to address the generic implications of the failure.

Some actions to be completed include :

DIRS is working to get an Information Notice out within the next few weeks to highlight the failure at LaSalle and similar other failures of this specific type of valve .

DIRS is evaluating the need for other forms of generic communications (e.g. , Generic Letter, Bulletin , etc.) to require licensees to respond to the agency.

Vendor Inspection branch will be going out to the vendor (Flowserve) for an inspection and Region Ill will supplement that inspection with SIT members familiar with the most recent issue.

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Logaras, Harral Sent: Tuesday, June 06, 2017 7:26 AM To: Jeffers, M ark

Cc: Barker, Allan <Allan .Barker@nrc.gov>; Heck, Jared <lared.Heck@nrc.gov>

Subject:

LaSalle SIT Update

Mark, I wonder if I could get update information on the LaSalle SIT exit plans. I have been working to keep some of our counterparts up to speed and I find the last such update I got was Wednesday, last week. Please tell me if there will be any such information sharing that I can sit in on so you don't have to do the work again just for the RSLO. Thank you.

Harral Logaras, MBA U.S. NRC Region Ill Regional Govern ment Liaison 630-829-9659 NRC 24 hour Operations Center 301-816-5100

Eight State Flags of Region-Ill

IA IL IN Ml MN MO OH WI

Link to the NRC website http://www.nrc.gov/

Link to the Award Winning NRC Information Digest {Click Here for the Latest Edition)

Link to the NRC Web Log or Blog http://public-blog.nrc-gatewav.gov/

Link to NRC Fact Sheets and Brochures http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/

From: Ieffers. Mark To: Loi:aras Harral Cc: Barker. Allan* Heck iared: Benjamin iamie; Chandrathil Prema: Mitlyni:, Viktoria

Subject:

RE: LaSalle SIT Update Date: Thursday. June 08, 2017 4:01:49 PM Attachments: LaSalle SIT Briefing Sheet - DRAFT C.docx Just to keep everyone in the loop, we are planning on exiting with LaSalle tomorrow morning. The team reviewed the updated analysis which provided some additional insight on the actual violation. Specifically, the failure analysis performed by an independent vendor combined with the effort done by the Special Inspection Team identified a design flaw in the valve itself (i.e. , originally, this was a manufacturing defect by the vendor, but now the vendor has determined it to be a flaw in the design of the valve itself). The vendor (Flowserve) is in the process of revising the 2013 Part 21 notification to include this design flaw.

The team is exiting with an apparent violation of 10 CFR 50, Criterion Ill, "Design Control."

It will be dispositioned under traditional enforcement since no performance deficiency exists (i.e., it was not within the ability of the licensee to foresee and correct) . Specifically, it would be unreasonable for the licensee to have identified th is desi n flaw of the valve from the vendor. (b)(5) Deliberative Privilege (b)(5) Deliberative Privilege attac e a summary o t e ey points t a t e team ma es w1 respect tot e operability of the valve. The next steps in the order process are to be briefing senior leadership (i.e., Cindy, Bill Dean, etc.) on the recommendation .

If anyone has any questions, please let me know.

Thank You, M ark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Jeffers, Mark Sent: Tuesday, June 06, 2017 8:03 AM To: Logaras, Harral <Harral.Logaras@nrc.gov>

Cc: Barker, Allan <Allan.Barker@nrc.gov>; Heck, Jared <Jared.Heck@nrc.gov>; Benjamin, Jamie (Jamie.Benjam in@nrc.gov) <Jam ie.Benjamin@nrc.gov>; Chandrathi l, Prema (Prema.Chandrathil@nrc.gov) <Prema.Chandrathil@nrc.gov>; M it lyng, Viktoria (Viktoria .Mitlyng@nrc.gov) <Vi ktoria.M it lyng@nrc.gov>

Subject:

RE: LaSal le SIT Update Duplicate Record

From: Heck, J ared To: Shuaibi Mohammed

Subject:

RE: OGC INVOVLEMENT IN LASALLE Date: Frid ay, June 09, 2017 12:48:00 PM Yes, Sara K. ~*~Lt;;,.J..t:.1.~~~,U.ll,,l~u.1.1.1....1.l,1;;"-,l,,l.l.l,,;;i.~.ll..l,,l,aL.U.U,..3.l.~.u...u.=:u..i~..l.l.:l~...i.=i~--

uestion i.e. (b)(S) Deliberative Privilege (b)(S) Deliberative Privilege l(b)(S) Deliberative Privilege I explained to her that the RA, Director of NRR, and DEDO will meet next week to go over the technical info and determine a path forward. I said I would update her after that. No work has begun in OGC at this point.

Jared From: Shua ibi, Mohammed Sent: Friday, June 09, 2017 11:17 AM To: Heck, Jared <Jared.Heck@ nrc.gov>

Subject:

OGC INVOVLEMENT IN LASALLE Jared, I understand from Cindy that you're going to be reaching out to OGC to engage them on the outcome of the LaSalle SIT and facilitate support on a path forward. In conversations with Mark, he did share with me that an attorney by the name of Sara is working with him .... l assume its Sara Kirkwood. Maybe you can start there and see if in fact she's the one that been engaged and how much is happening on her end on this item.

Thanks, Mohammed

From:

To:

Cc:

Subject:

Date:

Apologies. I spoke with Sara K. th is morning (not to be confused w ith Sarah P.).

From: Lemoncell i, Mauri Sent: Monday, June 12, 2017 9:16 AM To: Heck, Jared <Jared.Heck@nrc.gov>

Cc: Mould ing Patrick <Patrick.Mou ldin '@nrc.gov>; Kirkwood, Sara <Sara.Kirkwood@nrc.gov>

Subject:

RE (b)(S) Deliberative Privilege

Jared, Thanks so much for continuing to keep us in the loop. I talked with Sarah this morning and I think we are all on the same page. From my perspective no need to chat today. Will await the leadership meeting and can chat once you get some additional detail on the path forward.

Thanks again !

Original Message --------

From: "Heck, Jared" <Jared.Heck@nrc.gov>

Date: Mon, June 12, 2017 9: 13 AM -0400 To: "Lemoncelli, Mauri" <Mauri.Lemoncelli@nrc.gov>

CC: "Moulding, Patrick" <Patrick.Moulding@nrc.gov>, "Kirkwood, Sara"

< a a.

o d *c >

Subject:

RE: (b)(S) Deliberative Privilege Yes, it is. I spoke with Sara on Friday. I gave her the heads up that Cindy P., Bill Dean, and Mike Johnson will be meeting this week (tomorrow?) to discuss (hopefully decide) the next step. I will update you and Sara after that, unless you want to speak today.

Jared From: Lemoncell i, Mauri Sent: Sunday, Ju ne 11, 2017 9:49 PM To: Heck, Jared <Jared .Heck@nrc.gov>

Cc: Mould in Patrick <Patrick.Mould in nrc. ov>

Subject:

RE (b)(S) Deliberative Privilege Hi Ja red, Pat was on CWS on Friday, and I was on SL (can't shake a summer flu!).

Is t his by chance the LaSalle va lve issue? If so, Sa ra K. and I have both ta lked to Ken about it. We can set up a cal l with you .

Thanks!

Mauri From: Heck, Ja red Sent: Friday, June 09, 2017 10:33 AM To: Lemoncelli, M au ri <Mauri. Lemoncelli@nrc.gov>

Cc: Moul in P i k <Patrick.Mouldin >

Subject (b)(S) Deliberative Privilege

Mauri, It looks like Pat is out. Are you in? I want to brief ou on somethin brewing in the staff that may result in a decision (b)(S) Deliberative Privilege Ja red K. Heck Regional Counsel U.S. NRC Region Ill Tel. 630-829-9653

From: Heck, J ared To: Kirkwood Sara Subject : RE: LaSalle TS 3.5.1 Date: Thursday, June 15, 2017 9: 41 :00 AM Excellent! The slides were re ared b the SIT!(b)(S) Deliberative Privilege I (b)(S) Deliberative Privilege No decision was reached at the meeting where those slides were presented. The presentations was made by Region Ill with the RA, Director of NRR, and M. Johnson present (plus a large cast of supporting management and staff).

Jared From: Kirkwood, Sara Sent: Th ursday, June 15, 20 17 9:31 AM To: Heck, Jared <Jared .Heck@nrc.gov>

Subject:

RE: LaSa lle TS 3.5.1 Thanks Jared. I'm finding the slides very helpful.

From: Heck, Jared Sent: Thursday, Ju ne 15, 2017 10:29 AM To: Kirkwood, Sara <Sara.Kirkwood@ n rc.gov>

Subject:

LaSal le TS 3.5 .1 Sara, We are dealing with TS 3.5.1 Condition 8 .2.

Jared From: R3Scan@nrc.gov [mai1to :R3Scan@nrc.gov]

Sent: Thursday, Ju ne 15, 2017 9:31 AM To: Heck, Jared <Jared .Heck@nrc.gov>

Subject:

At t ached Image

From: Heck, Jared To: Kirkwood Sara

Subject:

FW: Attached Image Date: Thursday, June 15, 2017 9:05:00 AM Attachments: 0463 001 .od(

I will need to get you the TS but here is the technical presentation.

From: R3Sca n@nrc.gov [mai1to:R3Sca n@nrc.gov]

Sent: Thursday, Ju ne 15, 2017 8:52 AM To: Heck., Ja red <Jared.Heck@nrc.gov>

Subject:

Attached Image

From: Ieffers. Mark To: Loi:aras Harral; Barker Allan: Heck 1ared: Skokowski Richard; Chandrathil Pcema: Mitlyni: Yiktoria: .l.a!'.!l!llit.

Kenn eth Cc: Benjamin l am ie; Stoedter Karla

Subject:

RE: LaSa lle SIT Update Date: Friday. J une 16, 2017 3:27:1S PM Attachments: E170602t030957 NRC RA] 7-056.pdf To keep everyone in the loop, Cindy, Bill Dean, and Mike Johnson met this afternoon to discuss options going forward with the unresolved issue at LaSalle (i.e., the operability assessment of the Unit 1 HPCS injection valve) . From that meeting, the direction we receive was to o down arallel aths:

(b)(~~~~~~

1---------------------------

(b)(S) Deliberative Privilege (b)(S) Deliberative Privilege If anyone has any questions, please let me know.

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From : Jeffers, M ark Se nt: Th ursday, June 08, 2017 4 :02 PM To: Logaras, Ha rral <Harral.Logaras@nrc.gov>

Cc: Ba rker, Allan <Allan.Ba rker@nrc.gov>; Heck, Jared <Jared.Heck@nrc.gov>; Benjamin, Jamie (Jamie.Benjam in@nrc.gov) <J am ie.Benjami n@nrc.gov>; Cha ndrat hi l, Prema (Prema. Cha ndrat hil@ nre.gov) <Prem a .Cha nd ra th il@n re.gov>; M it lyng, Vi ktoria (Viktoria. M itlyng@nrc.gov) <Vi ktoria. M it lyng@nrc.gov>

Subject : RE: LaSa lle SIT Updat e Just to keep everyone in the loop, we are planning on exiting with LaSalle tomorrow morning. The team reviewed the updated analysis which provided some additional insight on the actual violation. Specifically, the failure analysis performed by an independent vendor combined with the effort done by the Special Inspection Team identified a design flaw in the valve itself (i.e., originally, this was a manufacturing defect by the vendor, but now the vendor has determined it to be a flaw in the design of the valve itself). The vendor (Flowserve) is in the process of revising the 2013 Part 21 notification to include this design

flaw.

The team is exiting with an apparent violation of 10 CFA 50, Criterion Ill, "Design Control. "

It will be dispositioned under traditional enforcement since no performance deficiency exists (i.e., it was not within the ability of the licensee to foresee and correct) . Specifically, it would be u * * * *

(b)(S) Deliberative Privilege Deliberativ I attached a "summary" of the key points that the team makes with respect to the opera 11ty of the valve. The next steps in the order process are to be briefing senior leadership (i.e., Cindy, Bill Dean, etc.) on the recommendation.

If anyone has any questions, please let me know.

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Jeffers, Mark Sent: Tuesday, Jun e 06, 2017 8:03 AM To: Logaras, Harral <HarraLLogaras@nrc.gov>

Cc: Ba rker, Allan <Allan.Barker@nrc.gov>; Heck, Jared <Jared.Heck@nrc.gov>; Benjamin, Jamie (Jamie.Benjamin@nrc.gov) <Jamie.Benjamin@ nrc.gov>; Chandrat hil, Prema

{Prema.Chandrathi l@nrc.iwv) <Prema.Chandrathil@nrc.gov>; Mitlyng, Viktoria (Viktoria.Mitlyng@nrc.gov) <Viktoria.Mit lyng@nrc.gov>

Subject:

RE: LaSa lle SIT Update The only remaining inspection activities for the LaSalle SIT include inspecting the operability of the Unit 1 High Pressure Core Spray injection valve (i.e. , the opposite unit's valve to the one that failed). The team has gone back and forth with the licensee on the development of information that would provide reasonable assurance of operability. The licensee has continuously been updating their operability based on new information developed/provided by the BWAOG, the valve vendor, specialty engineering firms , and an independent lab performing the fai lure analysis evaluation. The most recent delay was due to the delivery of the failure analysis report that was completed last Wednesday. The team is currently reviewing/inspecting the report and discussing the issues with the licensee.

The team is scheduled to make their recommendation on the operability of the Unit 1 valve by Wednesday . Depending on the recommendation , we will then schedule the exit meeting. Please let me know if you have any questions.

Additionally, for your awareness, headquarters entered into the LIC-504 process (i.e., risk informed decision making procedure developed after Davis Besse) to address the generic implications of the failure. Some actions to be completed include:

- DIAS is working to get an Information Notice out within the next few weeks to highlight the failure at LaSalle and similar other failures of this specific type of valve.

- DIAS is evaluating the need for other forms of generic communications (e.g. ,

Generic Letter, Bulletin, etc.) to require licensees to respond to the agency.

- Vendor Inspection branch will be going out to the vendor (Flowserve) for an inspection and Region Ill will supplement that inspection with SIT members familiar with the most recent issue.

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Loga ra s, Ha rral Sent: Tuesday, Jun e 06, 2017 7:26 AM To: Jeffers, Ma rk <Mark.Jeffers@ nrc.gov>

Cc: Barker, Allan <Allan .Barker@nrc .gov>; Heck, Jared <Jared .Heck@nrc.gov>

Subject:

LaSal le SIT Update

Mark, I wonder if I could get update information on the LaSalle SIT exit plans. I have been working to keep some of our counterparts up to speed and I find the last such update I got was Wednesday, last week. Please tell me if there will be any such information sharing that I can sit in on so you don't have to do the work again just for the RSLO. Thank you.

Ha rral Logaras, MBA U. S. NRC Region Ill Regiona l Government Lia ison 630-829-9659 NRC 24 hour Operations Center 301-816-5100 Eight State Flags of Region-Ill

IA IL IN Ml MN MO OH WI

Link to the NRC website http://www.nrc.gov/

Link to the Award Winning NRC Information Digest (Click Here for the Latest Edition)

Link to the NRC Web Log or Blog http://public-blog.nrc-gateway.gov/

Link to NRC Fact Sheets and Brochures http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/

From: Roberts Darrell To: Pederson Cynthia Cc: O"Brien. Kenneth; Shuaibi. Mohammed; Heck. iared: Ieffers. Mark; Lambert Kenneth

Subject:

RE: LaSalle Talking Points Date: Monday, June 19, 2017 2:57:19 PM Importance: High Cindy, With todav's news re: ootential shutdown the staff (Mark J. and Ken L.) informed me that (b)(S) Deliberative Privilege (b)(S) Deliberative Privilege they'd like to get first-hand knowledge from you as to

......,.......,.,,._.....,........,........,...,,_...,.....,..........,_.,...,,....,0......1-n your phone call w/ Enright.

The next step is for the staff to get with you Tuesday and gather that info as well as gain your alignment on the proposed path forward.

l(b)(S) Deliberative Privilege I've asked Mark to inform OEDO staff (Jeremy Bowen, etc.) of this recommendation from OE, for completeness in communications.

DJR From: Sh uaibi, Mohammed Sent: Monday, June 19, 2017 2:14 PM To: Johnson, Michael <Michael.Johnson@nrc.gov>; Pederson, Cynthia <Cynthia.Pederson@ nrc.gov>;

Dean, Bill <Bill.Dean@nrc.gov>; Bowen, Jeremy <Jeremy.Bowen@nrc.gov>; Clark, Theresa

<Theresa.Clark@ nrc.gov>

Cc: Roberts, Darrell <Darrell.Roberts@nrc.gov>; McDermott, Bria n <Bria n.McDermott@nrc.gov>;

Lubinski, John <John .Lubinski@nrc.gov>; O'Brien, Kenneth <Kenneth.O'Brien@ nrc.gov>; Louden, Patrick <Patrick.Louden@nrc.gov>; Lara, Ju lio <Ju li o.La ra@ nrc.gov>; Jeffers, Mark

<Ma rk.Jeffers@nrc.gov>; Alley, David <David.Al ley@ nrc.gov>; Coyne, Kevin <Kevin.Coyne@ nrc.gov>

Subject:

LaSal le Talking Points All, Attached for your use are the final set of talking points for LaSalle's HPCS valve issue.

This set incorporates the latest info from Exelon, regarding their intent to shut down Unit 1 to perform an inspection of the valve in question.

Please let me know if you have any questions.

Thanks,

Mohammed From: Mouldin& Patrick To: Heck l aced Cc: Kirkwood Sa ra; Lemoncelli. Mauri

Subject:

RE: LaSalle NRC Correspondence RA17-059

Amendment to Commitments for Reso lution of Anchor Darling Double Disc Gate Va lve Part 21 Issues Date: Wednesday,June 21, 2017 1:1 8:47 PM OK - sounds reasonable, given how imminently the licensee intends to initiate the shutdown.

From: Heck, Jared Sent: Wednesday, June 21, 2017 2:09 PM To: Moulding, Patri ck <Patrick.Moulding@nrc.gov>

Cc: Kirkwood, Sara <Sara.Kirkwood@nrc.gov>; Lemoncell i, Mauri <Mauri.Lemoncelli@nrc.gov>

Subject:

RE: LaSa lle NRC Correspondence RA17-059 - Amendment to Commitments for Resolut ion of Anchor Da rling Double Disc Gate Valve Part 21 Issues We are planning to develop a response letter, yes. At this point, it is envisioned as a simple acknowledgement letter that would issue from Region Ill. It would not be made public until after the shutdown, as the licensee treats its shutdown schedule as confidential commercial information.

From: Moulding, Patrick Sent: Wednesday, June 21, 2017 12:58 PM To: Heck, Ja red <Jared .Heck@nrc.gov>

Cc: Kirkwood, Sara <Sara.Kirkwood@nrc gov>; Lemoncelli, Mauri <Mauri.Lemoncel!i@nrc gov>

Subject:

RE: LaSa lle NRC Correspondence RA17-059 - Amendment t o Commitments for Resolut ion of Anchor Da rli ng Double Disc Gate Valve Pa rt 21 Issues Thanks, Jared -we've certainly appreciated your close coordination with Sara and the RIii technical experts throughout the process. I gave Ed a heads-up about the letter as well.

(b)(S) Deliberative Privilege is this

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From: Heck, Jared Sent: Wednesday, June 21, 2017 1:53 PM To: Moulding, Patrick <Patrick.M ou lding@nrc,tNY>

Cc: Kirkwood, Sara <Sara .Kirkwood@n rc.gov>

Subject:

RE: LaSa lle NRC Correspondence RA17-059 - Amendment to Commitments for Resolut ion of Anchor Darling Double Disc Gate Valve Part 21 Issues Special thanks to Sara K. for her excellent support to this point!

From: Moulding, Patrick Sent: Wednesday, June 21, 2017 12:06 PM

To: Heck, Ja red <Jared .Heck@nrc.gov>

Subject:

RE: LaSa lle NRC Correspondence RAl 7-059 - Amendment t o Commitments for Resolut ion of Anchor Da rling Double Disc Gate Valve Part 21 Issues Understood - thank you for letting us know.

From: Heck, Jared Sent: Wednesday, June 21, 2017 12:48 PM To: Kirkwood, Sara <Sa ra.Kirkwood@nrc.gov>

Cc: Lemoncelli, Mau ri <Mauri.Lemoncelli@nrc.gov>; Mouldi ng, Patrick <Patrick .Moulding@nrc.gov>

Subject:

FW: LaSal le NRC Correspondence RA17-059 - Amendment to Comm itments for Resolution of Anchor Darli ng Double Disc Gat e Valve Part 21 Issues FYI From: Pederson, Cynth ia Sent: Wednesday, June 21, 2017 7:59 AM To: Bowen, Jeremy <Jeremy.Bowen@nrc.gov>; Dean, Bil l <Bill,Dean@ nrc.gov>; Johnson, M ichael

<M ichael.Johnson@n rc.gov>; M ccree, Victor <Vict or.McCree@nrc.gov>; Brown, Frederick

<Frederick.Brown@nrc .gov>; Heck, Jared <Jared.Heck@nrc.gov>; McDermott, Brian

<Brian. McDermott@n re.gov>

Cc: Roberts, Da rrell <Darrell .Roberts@nrc.gov>; La ra, Julio <Julio.Lara@nrc.gov>; Skokowski, Richa rd

Subject:

FW: LaSal le NRC Correspondence RA17-059 -Amendment to Comm itments for Resolution of Anchor Darli ng Double Disc Gate Valve Part 21 Issues Note withholding under 2.390 until 24th so as not to forecast a shutdown (market influence).

Exelon's letter attached.

From: Stoedter Karla To: era~ ~im: Skokow~ chard* letters Mark* ,.,La""m""b.,.e.,_.rt'""'K. , e. .,n""'ne,. .t,. ,h: Pelke Paul; Chandrathit Prema S ubject: ... EAJ7XXXlaSaUe L Jeady for final.doc (b)(5) Date: Frida une 23 2017 :13:01 AM Attachments: (b)(S) Deliberative Privilege Comments are attached for consideration.

From: Ieffers. Mark To: Stoedter Karla: Skokowski m ambert Kenneth

Subject:

RE: LaSalle press release an b 5 Date: Thu rsday. June 22, 2017 7:08:12 AM How is the letter going for Lasalle?

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Stoedte r, Karla Sent: Wed nesday, June 21, 2017 2:04 PM To: Jeffers, Mark <Mark.Jeffers@nrc.gov>; Chandrathi l, Prema <Prema.Cha ndrath il@n rc.gov>

Subject:

LaSal le press release andlfil]

(b)(S) Deliberative Privilege T01\ 01

I As discussed, the acknowledgement letter should not be issued until after June 24, 2017, due to the proprietary nature of the licensee's letter. Rick and his group are working on the letter as we speak.

l (b)(S) Deliberative Privilege I * *

there 1s no need to issue a press release. I am 1n the process of revising the communications plan based on feedback from divisional management.

We will continue working the Q and As since the licensee plans to issue a press release on the shutdown in the near future.

I will be at Clinton tomorrow, but plan to work the communications plan on Friday.

Thanks ,

Karla Karla Stoedter, Chief Region Ill Division of Reactor Projects - Branch 1 630-829-9731 (office)

From: Hilton Nick To: Skokowski Richard; Peralta I uan; Peduzzi Francis Cc: O"Brien Kenneth; l effers Mark; Benjamin l amie; Heck. i ared: Lambert Kenneth; Holahan Patricia

Subject:

Hb)/5) behberat1ve Pnv,lege I Date: Thursday. June 15, 2017 3:01:13 PM Yes, OE supports the concept. © I believe we should strike the last phrase, starting at "because the HPCS system is and has been inoperable for approximately 6 weeks . . . " in large part because we (the NRC) have not concluded it's been inoperable for 6 weeks . If we've done so, it's very recently.

That said, my favorite approach that I've heard so far, is to describe our issues, conclude the valve in inoperable, and then "requi re" them to follow thei r TS for an inop valve (yes, that gives them 14 days to shut down) .

Is there a set of (draft) briefing slides on this topic?

Thanks, Nick From: Skokowski, Richard Sent: Th ursday, June 15, 2017 2:09 PM To: Hilton, Nick <N ick. Hilton@nrc.gov>; Peralta, Juan <Juan .Peralta@ nrc.gov>; Peduzzi, Fra ncis

Cc: O'Brien, Kenneth <Ken neth.O'Brien@nrc.gov>; Jeffers, Ma rk <Ma rk.Jeffers@nrc.gov>; Benjamin, Jamie <Jam ie.Benj am in @nrc.gov>; Heck, Jared <Jared .Heck@nrc.gov>; Lambert, Ken net h

Subject:

l (b)(S) Deliberative Privilege Good afternoon, (b)(S) Deliberative Privilege VR Rick

From: Hilton Nick To: O"Brien Kenneth; Skokowski Richard Cc: Lemoncelli Mauri; Gulla Gerald

Subject:

FW: ACKNOWLEDGEMENT OF COMMITMENTS IN LEITER DATED JUNE 20, 2017, FOR RESO LUTION OF ANCHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSUES - LASALLE COUNTY STATION - UNITS 1 AND 2 Date: Monday, June 26, 2017 4:23:54 PM hvs) Qeljheratjye PciYileae

!(b)(S) Deliberative Privilege I hanks for setting a good threshold!

From: Clay, Jim Sent: Monday, Jun e 26, 2017 5:15 PM To: Peduzzi, Francis <Francis .Peduzzi@nrc.gov>; Pera lta, Juan <J uan.Peralta@nrc.gov>; Hi lton, Nick

<Nick.Hilton@nrc.gov>; Bowen, Jeremy <Jeremy.Bowen@nrc.gov>; RidsNrrDorl Lpl3 Resource

<RidsNrrDorlLpl3.Resource@ nrc.gov>; RidsNrrPMLaSa ll e Resource

<RidsNrrPMLaSal le.Resou rce@nrc.gov>; RidsN rrDirslrib Resource

<RidsNrrDirslrib. Resource@nrc.gov>; Johnson, M ichael <Michael.Johnson@nrc.gov>; Holahan, Patricia <Patricia.Holahan@nrc.gov>; Pederson, Cynthia <Cynthia.Pederson@nrc.gov>; Roberts, Darrell <Darrell.Roberts@nrc.gov>; Shuaibi, Mohammed <Mohammed.Shuaibi@nrc.gov>;

Marshfield, Ma rk <Mark.Marshfield@nrc.gov>; Casey, Lau ren <Lauren .Casey@nrc.gov>; Skokowski, Richard <Richard.Skokowski@nrc.gov>; Lambert, Kenneth <Kenneth.Lambert@nrc.gov>; Barker, All an <Al lan.Barker@nrc.gov>; Logaras, Harral <Harral.Logaras@nrc.gov>; Chandrath il, Prema

<Prema .Chandrathil@nrc.gov>; Holahan, Patricia <Patricia.Holahan@nrc.gov>; Dean, Bill

<Bill.Dean@nrc.gov>; O'Brien, Kennet h <Kenneth.O'Brien@ nrc.gov>; Mitlyng, Viktoria

<Viktoria.Mitlyng@nrc.gov>

Subject:

ACKNOWLEDGEMENT OF COMMITMENTS IN LETIER DATED JUN E 20, 2017, FOR RESO LUTION OF ANCHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSU ES - LASALLE COUNTY STATION - UNITS 1 AND 2 The subject document has been signed and sent to ADAMS DPC for final profiling. Please use link below to review this document.

View ADAMS Properties ML17177A697 Open ADAMS Document (ACKNOWLEDGEMENT OF COMMITMENTS IN LETTER DATED JUNE 20, 2017. FOR RESOLUTION OF ANCHOR DARLING DOUBLE DISC GATE VAL VE PART 21 ISSUES - LASALLE COUNTY STAT ION - UNITS 1 AND 2)

Jim Clay, WCA Certified Administrative Assistant to Cynthia Pederson Regional Administrator, Region Ill Phone: 630-829-9657 Email: jim.clay@nrc.gov w<A.

From: Benjamin 1amie To: Kozak Laura

Skokowski Richard

Subject:

FW: LaSalle Exit Date: Thursday, June 08, 2017 3:10:19 PM From: Benjamin, Jamie Sent: Thursday, June 08, 2017 3:06 PM To: Jeffers, Mark <Mark.Jeffers@ nrc.gov>; Rodriguez, Lionel <Lionel. Rod riguez@ nrc.gov>; Dun lop, Andrew <Andrew.Dunlop@nrc.gov>; Phill ips, Charles <Charles.Phill ips@nrc.gov>; Fa rnan, Michael

<Michael.Fa rn an@nrc.gov>; O'Brien, Kenneth <Kennet h.O'Bri en@nrc.gov>

Cc: Stoedter, Ka rla <Ka rla.Stoedt er@nrc.gov>

Subject:

RE: LaSa lle Exit Exit is set for tomorrow at 9am. Licensee is getting us a bridge line.

~: l(b)(S) Deliberative Privilege

3. Several comments that may make it to the report.

From: Jeffers, M ark Sent: Th ursday, June 08, 2017 2:48 PM To: Benja mi n, Jam ie <Jamie.Benjamin@nrc.gov>

Cc: Stoedter, Karla <Karla.Stoedter@nrc.gov>

Subject:

LaSal le Exit

Jamie, From Bill Dean and Cindy, they are supportive of exiting tomon-ow. Please get with the licensee and schedule a time. Ken and I will be there. Preferably 9:00 AM.

(b)(S) Deliberative Privilege nv1 ege by then.

Thanks, Mark Sent from my iPhone. Please forgive any typos.

From: Ben jamin 1amie To: leffers Mark* Stoedter Karla; Skokowski Richard* O"Brjen Kenneth* Shuaibi Mohammed: Lara IYlio; l.w.!d.en.

Patrick; Ruiz. Robert Cc: Rodriguez Lionel: Dunlop Andrew; Phillips Charles; Farnan Michael

Subject:

FW: LaSalle letter regard ing Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues.

Date: Friday. June 02, 2017 9:09:52 AM Attachments: RAJ 7-056 - Commitments for Resolution of Anchor Darling Double Disc Gate valve part 21 Issues odf Importance: High The licensee sent me a copy of t heir approve This is not a draf t letter but has not been mailed yet.

They told me that t hey will send it out today by COB. They want ed me to ta ke a look at it to see if it met our expectat ions.

I thought that they committed to replacing all 4 va lves du ring their next Mode 4 opportunity, planned or unpla nned. Letter does not read t hat way.

Ken - You spoke wit h th e licensee directly ...

From: Kusumawatimurray, Put ri:(GenCo-Nuc) ri.Kusumawat im urray@exeloncorp .com

Sent: Friday, June 02, 2017 8:51 AM To: Benjamin, Jamie <Jamie.Benjamin@nrc.gov>

Subject:

[Externa l_Sender] LaSa lle letter rega rd ing Commitments for Resolut ion of Anchor Darling Double Disc Gate Valve Part 21 Issues.

Importance: High

Jamie, Please see t he attached letter t hat has been reviewed by LaSa lle's management regarding commitments for resolut ion of Anchor Darl ing Double Disc Gate Valve Part 21 issues based on May 25, 2017 discussion. We intend to subm it t he letter today pending any feedback from the NRC.

Please let me know if any quest ions or concerns .

Thank you, Dwi Murray Principal Regulatory Engineer Regulatory Assurance - LaSalle County Station

,,: ExelonGcnnrahon.

8 15-415-28 14 Putrj.Kusumawatimu r ray@exelo o corn.com

From: Pederson Cynthia To: Heck laced: Skokowski Richard

Subject:

FW: LaSalle Options Date: Friday. June 16, 2017 12:22:30 PM Attachments: Qpt ion tJRR Revision t une 16 REV 5.docx From: Jeffers, M ark Sent: Friday, June 16, 2017 12:16 PM To: O'Brien, Kenneth <Ken neth.O'Brien@nrc.gov>; Shua ibi, Moha mmed

<Mohammed.Shu aibi@nrc.gov>; Pederson, Cynt hia <Cynthia.Pederson@nrc.gov>; Lara, Julio

<Julio.La ra@ nrc.gov>; Louden, Patrick <Patrick.Louden@nrc.gov>

Cc: Stoedter, Ka rla <Ka rla.Stoedt er@nrc.gov>

Subject:

RE: LaSalle Options Updated the Options paper to address a couple additional comments . Please note that NRR does not support these changes from the orig inal that was presented this morning.

Kevin Coyne is currently discussing these discrepancies with Ken now.

Than k You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Jeffers, Mark Sent: Friday, Jun e 16, 2017 11:31 AM To: O'Brien, Kenneth <Kenneth.O'Brien@nrc.gov>; Sh uaibi, M ohammed (Mohammed.Shuaibi@nrc.gov) <Mohammed .Shua ibi@nrc.gov>; Pederson, Cynt hia (Cynt hia .Pederson@n rc.gov) <Cynthia .Pederson@nrc.gov>; Lara, Julio (J ulio .Lara@ nrc.gov)

<Ju lio ,Lara@nrc.gov>; Louden, Patrick (Patrick.Louden@nrc.gov) <Patrick. Louden@nrc.gov>

Cc: Stoedter, Ka rl a (Karla Stoedt er@nrc gov) <Karla.Stoedter@nrc.gov>

Subject:

FW: LaSalle Options All ,

Please find the attached revision to the Options paper to address the comments from this morning. I have shared it with headquarters (i.e., Kevin Coyne) and he is still reviewing ;

however, I wanted to share with everyone as soon as possible to correct any discrepancies. If there are any questions, comments, or concerns , please let me know.

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798

From: Stoedter Karla To: ~

Cc: Skokowski Richard

Subject:

FW: LaSalle Valve Issue Da te : Friday.June 23, 2017 10:34:15 AM

Jim, Looks like OE does not need to concur based on Nick's response below. They just need a copy.

Karla Karla Stoedter, Chief Region Il l Division of Reactor Projects - Branch 1 630-829-9731 (office)

From: Hilton, Nick Sent: Friday, June 23, 2017 10:33 AM To: Stoedter, Karla <Karla.Stoedter@nrc.gov>

Subject:

RE: LaSa lle Valve Issue Copy is fi ne, thanks.

From: St oedter, Karla Sent: Friday, June 23, 2017 11:25 AM To: Hi lton, Nick <Nick.Hilton@nrc.gov>

Subject:

RE: LaSa lle Valve Issue Do you all need to be on concurrence or just want a copy when it is issued.

Karla Stoedter, Chief Region Ill Division of Reactor Projects - Branch 1 630-829-9731 (office)

From: Hilton, Nick Sent: Friday, June 23, 2017 9:07 AM To: Skokowski, Richard <Richard.Skokowski@nrc.gov>; Pera lta, Juan <Juan. Peralta@nrc.gov>;

Holaha n, Patricia <Patricia.Holahan@nrc,gov>; Peduzzi, Francis <Francis,Peduzzi@nrc.gov>

Cc: Lambert, Kenn eth <Kenn eth .Lambert@nrc. gov>; Pelke, Paul <Paul .Pelke@nrc.gov>; Jeffers, M ark

<M ark.Jeffers@nrc.gov>; Cha ndrathi l, Prema <Prema .Chandrathil@nrc.gov>; St oedter, Karla

<Ka rla.Stoedter@ nrc.gov>; Orth, Steven <Steyen.Orth@nrc.gov>; O'Brien, Kenneth

Subject:

RE: LaSa lle Valve Issue I like the plan (b)(S) Deliberative Privilege

From : Skokowski, Richard Sent : Thursday, June 22, 2017 6:22 PM To: Pera lta, Jua n <Juan.Peralta@nrc.gov>; Hi lton, Nick <Nick.Hilt on@nrc.gov>; Holahan, Patricia

<Patricia.Holahan@nrc.gov>; Peduzzi, Francis <Francis.Peduzzi@nrc.gov>

Cc: Lambe rt, Kenneth <Kenneth. Lambert@nrc.gov>; Pelke, Paul <Pa ul. Pelke@nrc.gov>; Jeffers, M ark

<Mark.Jeffers@nrc gov>; Chandrathi l, Prema <Prema Chandrathil@nrc.gov>; Stoedter, Karla

<Karla.Stoedt er@nrc.gov>; Orth, Steven <Steven.O rth@nrc.gov>; O'Brien, Kennet h

Subject:

LaSa lle Va lve Issue Good afternoon, Just trying to keep folks up to date on the LaSalle Valve issue. The licensee has agreed to shut down and look at the valve in question, we should have the results early next week.

(b)(S) Deliberative Privilege (b)(S) Deliberative Privilege he decision was ma e to s1mp e prov1 ea response tot e 1censee s ette . . e era ive I

Pr1v1le e Having said that, I just wanted to give a check to see if there were any concerns with this approach as we go forward, and to see if anyone is aware of any precedents for using this approach or contrary to using this approach?

VR Rick

From: Pederson Cynthia To: Skokowski Richard

Subject:

FW: Option Table for LaSalle Special I nspection Date: Friday. June 16, 2017 12:38:22 PM Attachments: Qpt ion tJR R Revision t un e 16 REV 5 Clean.docx From: Coyne, Kevin Sent: Friday, Ju ne 16, 2017 12:31 PM To: McDermott, Brian <Brian.McDermott@nrc.gov>; Dean, Bill <Bil l.Dean@nrc.gov>; Lubinski, Jo hn

<John.Lubinski@nrc.gov>; Pederson, Cynthia <Cynthia.Pederson@nrc.gov>; O'Brien, Kenneth

<Kenneth .O'Brien@nrc.gov>; Shuaibi, Mohammed <Mohammed .Shuaibi@nrc.gov>; Roberts, Darrell

<Darrell.Roberts@ nrc.gov>

Cc: Jeffers, Ma rk <Mark.Jeffers@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>; Evans, M ichele

<Michele.Evans@nrc.gov>

Subject:

Option Table for LaSa lle Specia l Inspection Folks -

Just worked through a few issues with Ken - so here's the latest/last version of the options Table for LaSalle. I'll bring hardcopies for people in HQ.

Kevin

From: Ieffers. Mark To: Lambert Kenneth ; Skokowski Richard Cc: Stoedter Karla* Benjamin 1am ie

Subject:

Fwd: La Salle NRC Correspondence RA17-0S9

Amendment to Commitments for Resolution of Anchor Da rling Double Disc Gate Va lve Part 21 Issues Date: Wednesday, J une 21, 2017 7:44:02 AM Attachments: NRC RA17-0S9.pd[

Ken/Rick, We received a cowwitweot Jetter l(b)(5) Deliberative Privilege frorWeExelon.

, (b)(S) Deliberative Privilege s _m_o_r_e_s_h_o-rt'l""'y can d~1s-*c_u_s_ - .-----------

Thanks Mark From: "Stoedter, Karla" <Karla.Stoedter@ nrc.gov>

Subject:

FW: LaSalle NRC Correspondence RA 17-059 - Amendment to Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues Date: 2 1 June 201 7 05:45 To: "O'Brien, Kenneth" <Kenneth.O'Brien@ nrc.gov>, "Shuaibi, Mohammed"

<Mohammed.Shuaibi@ nrc.gov>, "Jeffers, Mark" <Mark.Jeffers@nrc.gov>, "Louden, Patrick" <Patrick.Louden@nrc.gov>

Here is the updated commitment letter from LaSalle. The letter is proprietary until June 24th.

Thanks, Karla Karla Stoedter, Chief Region Il l Division of Reactor Projects - Branch 1 630-829-9731 (office)

From: Kusumawatimu rray, Put ri:(GenCo-Nuc) [ma ilto:Put ri.Kusumawat imu rray@exeloncorp .com)

Sent: Tuesday, Jun e 20, 2017 6:33 PM To: Stoedt er, Ka rla <Ka rla.Stoedt er@nrc.gov>; La ra, Ju li o <J ulio .Lara@nrc.gov>

Subject:

[Externa l_Sender] LaSa ll e NRC Correspondence RAl 7-059 - Amendment to Commitments for Resolution of Anchor Darling Double Disc Gate Va lve Part 21 Issues Karla and Ju lio, For your information. The attached letter was submitted electronically through EIE to the NRC on June 20, 2017.

Please let me know of any questions.

Thank you, Dwi Murray Principal Regulatory Engineer Regulatory Assurance - LaSalle County Station 815-415-2814 Putri. Kusu mawati mu rray@exeloncorp.com

From: Ieffers. Mark To: Skokowski Richard

Subject:

Fwd: LaSalle SIT Presen tation Date: Thu rsday, June 15, 2017 3:06:02 PM Attachments: LaSalle SIT Recom mendation

Rev 0,RJ>tx Thanks, Mark Sent from my iPhone. Please forgive any typos.

From: "Jeffers, Mark" <Mark.Jeffers@nrc.gov>

Subject:

LaSalle SIT Presentation Date: 13 June 2017 07:14 To: "Coyne, Kevin" <Kevin.Coyne@nrc.gov>

Kevin, I believe that you are on the LaSal le "Mgmt Discussion" meeting at 12:30 today. I have a presentation (attached) that I will be going over and am trying to find the best way of getting the copies to HQ management. Do you have any recommendations on who I can contact to get the slides printed for the HQ staff?

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798

From: Benjamin 1amie To: Kozak Laura

leffers Mark Cc: Skokowski Richard

Subject:

RE: LaSalle Exit Da te : Thursday, June 08, 2017 3:21 :27 PM Makes sense.

From: Kozak, Laura Sent: Th ursday, Ju ne 08, 2017 3:20 PM To: Benjami n, Jam ie <Jamie.Benjamin@nrc.gov>; Jeffers, Ma rk <Ma rk.Jeffers@ nrc.gov>

Cc: Skokowski, Richard <Richard.Skokowski@nrc.gov>

Subject:

RE: LaSa lle Exit My recollection of traditional enforcement is that you would call it an "apparent violation" and prepare for an enforcement panel, but this is sketchy. I would consult with EICS.

So no SOP needed on this issue since there is no PD.

From: Benjamin, Jamie Sent: Th ursday, Ju ne 08, 2017 3:14 PM To: Kozak, La ura <Laura .Kozak@nrc.gov>; Jeffers, Ma rk <Mark.Jeffers@nrc.gov>

Cc: Skokowski, Richard <Richard .Skokowski@nrc.gov>

Subject:

RE: LaSa lle Exit Panel has not been held. Traditional enforcement because we do not believe that there is a PD but we do believe that there is a violation.

Do we need to hold a panel before we exit?

From: Kozak, Laura Sent: Thursday, Ju ne 08, 2017 3:13 PM To: Benjami n, Jam ie <Jamie.Benjamin@nrc.gov>

Cc: Skokowski, Richard <Richard.Skokowski@nrc.gov>

Subject:

RE: LaSa lle Exit I do not understand SUI, NOV for item 1. Are we going traditional enforcement for some reason? Has a panel been held?

From: Benjamin, Jamie Sent: Thursday, Ju ne 08, 2017 3:10 PM To: Kozak, La ura <Laura .Kozak@nrc.gov>; Skokowski, Richard <Richard .Skokowski@nrc.gov>

Subject:

FW: LaSal le Exit From: Benjamin, Jamie

Sent: Thursday, Ju ne 08, 2017 3:06 PM To: Jeffers, Ma rk <Mark.Jeffers@nrc gov>; Rodriguez, Lionel <Ljone LRodrjguez@nrc.gov>; Dunlop, And rew <And rew.Dun lop@nrc.gov>; Phill ips, Charles <Charles.Pbil lips@nrc.gov>; Farna n, M ichael

<Michael.Fa rn an@nrc.gov>; O'Brien, Kenneth <Kenneth.O'Bri en@ nrc.gov>

Cc: Stoedter, Karla <Karla .Stoedter@nrc.gov>

Subject:

RE: LaSa lle Exit Duplicate Record

From: Ieffers. Mark To: Skokowski Richard

Subject:

RE: !(b)(5) Deliberative Pri vilege Date:

I~~~ii~ I Thursda~hune 2~ 201 7 12:52:01 PM Attachments: p noer uve (b)(S) Deliberative Privilege (b)(S) Deliberative Privilege in some o you had in the document.

Thank You, Mark Jeffers Bra nch Chief I RIii DRS EB2 I x9798 From: Skokowski, Richard Sent: Th ursday, Ju ne 22, 20 17 12:39 PM To: Jeffers, Ma rk <Mark.Jeffers@ nrc.gov>

Subject:

RE: (b)(S) Deliberative Privilege j(b)(S) Deliberative Privilege !As for precedents, 1 would say we send reply letters routinely without of press releases , I am not sure if commitment letter replies get a press release, but I'll do some research with NRR since they are more likely to receive the commitment letters.

Attach is the direction we were taking , still very draft.

From: Jeffers, M ark Sent: Th ursday, Ju ne 22, 2017 11:35 AM To: Stoedt er, Ka rla <Karla.Stoedter@nrc.gov>; Skokowski, Richa rd <Richard.Skokowski@nrc.gov>;

Lam bert Kennet h <Kenneth .Lambertraln rc.gov>

Subject (b)(5) Deliberative Privilege Also. I had a conversation with Prema. j(b)(S) Deliberative Privilege I l(b)(S) Deliberative Privilege I uo we nave any upE regarding this? Should we reach out to OE?

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Jeffers, M ark Sent: Th ursday, Ju ne 22, 2017 7:08 AM

To: Stoedter, Ka rla <Ka rla.St oedt er@nrc.gov>; Skokowski, Richa rd (Richard.Skokowski@ nrc.gov)

<Richard.Skokowski@nrc.gov>; Lambe rt, Kenneth (Kenneth.Lambert@n rc.gov)

How is the letter going for Lasalle?

Thank You, Mark Jeffers Branch Chief I RIii DRS EB2 I x9798 From: Stoedter, Karla Sent: Wednesday, June 21, 2017 2:04 PM To: Jeffers Ma rk <Ma rk.Jeffers nrc. ov>* Chandrat hi l, Prema <Prema.Chand rathil @nrc.gov>

Subject (b)(5) Deliberative Privilege (b)(S) Deliberative Privilege Rick and his group are (b)(S) Deliberative Privilege I am in

,___"""'l"C~e~p::-:r:-=o"='c'="es~s=--=-or-r::-::e~v~1s~in~g::""ff=-="""==~~==-=r=-=-===i-='="'!'==~:-==-=1v""!"!1'="s1~0nal management.

We will continue working the Q and As since the licensee plans to issue a press release on the shutdown in the near future.

I will be at Clinton tomorrow, but plan to work the communications plan on Friday.

Thanks, Karla Karla Stoedter, Chief Region Ill Division of Reactor Projects - Branch 1 630-829-9731 (office)

From: Pederson Cynthia To: Skokowski Richard Cc: Heck tared: O"Brien. Kenneth: Shuaibi Mohammed: Lara !ulio: Louden Patrick; Roberts Darrell

Subject:

RE: LaSalle support form OGC Date: Friday. June 16, 2017 11:52:10 AM Thanks Rick From: Skokowski, Richard Sent: Friday, June 16, 2017 11:22 AM To: Pede rson, Cynthia <Cynthia .Pede rson@nrc.gov>

Cc: Heck, Jared <Jared.Heck@nrc.gov>

Subject:

LaSal le support form OGC

Cindy, Based on a discussion with Jared, the Deliberative Pri concept has been briefed through Sara Kirkwood , through Patrick Moulding (Assistant General Counsel for Materials Litigation and Enforcement) to Ed Williamson (direct report to General Counsel) . It is my understanding that Mr. Williamson is aware of the concept, althou h he did not indicate his position, Ms. Kirkwood and Mr. Moulding can support the concept (b)(S) Delibe although they would need to hear the rest of the Agency's perspectives and see the actual documents before making any final decisions.

VR Rick

LaSalle High Pressure Core Spray Injection Valve (2E22-F004) Stem to Disc Separation (b)(S) Deliberative Privilege

From:

To:

Cc:

Subject:

Date:

Yes, OE supports the concept. © (b)(S) Deliberative Privilege Thanks, Nick From: Skokowski, Richard Sent: Th ursday, June 15, 2017 2:09 PM To: Hilton, Nick <N ick. Hilton@nrc.gov>; Peralta, Juan <Juan .Peralta@ nrc.gov>; Peduzzi, Fra ncis

Cc: O'Brien, Kenneth <Ken neth.O'Brien@nrc.gov>; Jeffers, Ma rk <Ma rk.Jeffers@nrc.gov>; Benjamin, Jamie <Jam ie.Benj am in @nrc.gov>; Heck, Jared <Jared.Heck@nrc.gov>; Lambert, Ken net h

Subject:

l(b)(S) Deliberative Privilege Good afternoon, (b)(S) Deliberative Privilege VR Rick

From: Peralta Iua o To: Het 1ared Subject : RE((b)(5) Deliberative Privilege Date: Thursday, June 15, 2017 3:41 :55 PM

!Outside of Scope From: Heck, Ja red Sent: Thursday, Ju ne 15, 2017 4:36 PM To: Peralta, Juan <Juan.Pera lta@nrc. ov>

Subject:

RE: (b)(S) Deliberative Privilege Outside of Scope Jared From: Peralt a, Juan Sent: Thursday, Ju ne 15, 2017 1:40 PM To: Heck., Jared <Jared .Heck@nrc.gov>

Subject:

RE: !(b)(S) Deliberative Privilege Hi Jared! How's everything over there?

From: Heck, Ja red Sent: Thursday, Ju ne 15, 2017 2:11 PM To: Skokowski, Richard <Richard.Skokowski@nrc.f;NY>; Hi lton, Nick <Nick.H ilton@nrc.gov>; Pera lta, Juan <Juan .Pera lt a@ nrc.gov>; Peduzzi, Francis <Francis. Peduzzi@n rc.gov>

Cc: O' Brien, Kennet h <Kenneth.O'Brien@nrc.gov>; Jeffers, Mark <Mark.Jeffers@nrc.gov>; Benjamin, Jamie <Jam ie.Benjamin@nrc.gov>; Lambert, Kenneth <Kenneth.Lambert@nrc.gov>; Kirkwood, Sara

Subject:

RE: !(b)(S) Deliberative Privilege l(b)(S) Deliberative Privilege Jared

From: Skokowski, Richard Sent: Thursday, June 15, 2017 1:09 PM To: Hilton, Nick <Nick.Hilton@nrc.gov>; Peralta, Juan <Juan.Pera lta@nrc.gov>; Peduzzi, Francis

Cc: O'Brien, Kennet h <Kenneth .O'Brien@nrc.gov>; Jeffers, M ark <Ma rk.Jeffers@nrc. gov>; Benjamin, Jamie <Jamie.Benjam in@nrc.gov>; Heck, Ja red <Jared.Heck@nrc.gov>; Lambert, Kenneth

Subject:

l(b)(S) Deliberative Privilege Good afternoon, (b)(S) Deliberative Privilege VR Rick

From:

To:

Subject:

Date:

Jared-My cell phone i~(b)(6) I'm off tomorrow but do have a window of availability from like 10:30-3 eastern.

I'll be teleworking Monda* b)(6)

Thanks, ....- - - - - -

Sara From: Heck, Ja red Sent: Thursday, Ju ne 15, 2017 2:11 PM To: Skokowski, Richard <R ichard .Skokowski@n rc.gov>; Hilton, Nick <Nick.Hilton@ nrc.gov>; Peralta, Juan <Juan. Pera lta @nrc.gov>; Peduzzi, Fra ncis <Francis. Peduzzi@nrc.gov>

Cc: O'Brien, Kenneth <Ken neth.O'Brien@ nrc.gov>; Jeffers, Ma rk <Ma rk.Jeffers@nrc.gov>; Benjamin, Jamie <Jam ie.Benjam in @nrc.gov>; Lambert, Kenneth <Kenneth.Lambert@n rc.gov>; Kirkwood, Sara

<Sara. Ki rkwood@ n re. gov>

Subject:

RE: l(b)(S) Deliberative Privilege I (b)(S) Deliberative Privilege Jared From: Skokowski, Richard Sent: Thursday, June 15, 2017 1:09 PM To: Hilton, Nick <Nick.Hilton@nrc.gov>; Pera lta, Juan <Juan.Peralta@nrc.gov>; Peduzzi, Francis

<Francis.Peduzzi@nrc.gov>

Cc: O'Brien, Ken net h <Kenneth.O'Brien@nrc.gov>; Jeffers, M ark <Mark.Jeffers@nrc.gov>; Benjam in, Jamie <Jamie.Benjam in@nrc.gov>; Heck, Jared <Jared .Heck@nrc.gov>; Lambert, Kenneth

Subject:

!(b)(S) Deliberative Privilege Good afternoon, (b)(S) Deliberative Privilege VR Rick

From: Skokowski Richard To: Hilton Nick* Peralta 1uan; Hay Michael: Kowal Mark: Bickett Brice Cc: Peduzzi. Francis; Holahan Patricia; Lambert Kenneth; leffers. Mark; Heck 1ared

Subject:

Hb)(S) Deliberative Privilege I Date: Friday.June 16, 2017 3:45:36 PM Good afternoon, (b)(S) Deliberative Privilege

Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

ACKNOWLEDGEMENT OF COMMITMENTS IN LETTER, DATED JUNE 20, 2017, FOR RESOLUTION OF ACHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSUES - LASALLE COUNTY STATION - UNITS 1 AND 2

Dear Mr. Hanson:

(b)(S) Deliberative Privilege

(b)(S) Deliberative Privilege Sincerely, Cynthia D. Pederson Regional Admin istrator Docket Nos. 50-373, 50-374 License Nos. NPF-11, NPF-18 cc: State of Illinois Distribution:

Jeremy Bowen RidsNrrDorllpl3 RidsNrrPMLaSalle RidsNrrDirslrib Resource Michael Johnson William Dean Patricia Holahan

Cynthia Pederson Darrell Roberts Ken O'Brien Mohammed Shuaibi Juan Peralta Mark Marshfield Lauren Casey Richard Skokowski Ken Lambert Allan Barker Harral Logaras Viktoria Mitlying Prema Chandrathil Concurrence; Lambert I Skokowski / Stoedter/ Jeffers/ Louden/ O'Brien/ Pederson

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Il l 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

ACKNOWLEDGEMENT OF COMMITMENTS IN LETTER, DATED JUNE 20, 2017, FOR RESOLUTION OF ANCHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSUES - LASALLE COUNTY STATION- UNITS 1 AND 2

Dear Mr. Hanson:

(b)(S) Deliberative Privilege

B. Hanson . 2.

(b)(S) Deliberative Privilege Cynthia D. Pederson Regional Administrator Docket Nos. 50-373, 50-374 License Nos. NPF-11 , NPF-18 cc: State of Illinois

ML 17 OFC NAME KLambert:ic RSkokowski KStoedter MJeffers PLouden KO'brien CPederson DATE I /17 I /17 I /17 I /17 I /17 I /17 I /17 EA-17-XXX Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

ACKNOWLEDGEMENT OF COMMITMENTS IN LETTER, DATED JUNE 20, 2017, FOR RESOLUTION OF ACHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSUES - LASALLE COUNTY STATION

Dear Mr. Hanson:

(b)(S) Deliberative Privilege

(b)(S) Deliberative Privilege Sincerely, Cynthia D. Pederson Regional Administrator Docket Nos. 50-373 License Nos. NPF-11 cc: State of Illinois Distribution:

Jeremy Bowen RidsNrrDorlLpl3 RidsNrrPMLaSalle

RidsNrrDirslrib Resource Michael Johnson William Dean Patricia Holahan Cynthia Pederson Darrell Roberts Ken O'Brien Mohammed Shuaibi Juan Peralta Mark Marshfield Lauren Casey Richard Skokowski Ken Lambert Allan Barker Harral Logaras Viktoria Mitlying Prema Chandrathil Concurrence; Lambert/ Skokowski / Stoedter/ Jeffers / Louden / O'Brien / ~RR: Dean / Oli-:-

Holahan / OGG: Kirkwooa / Skokowski / Pederson

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

ACKNOWLEDGEMENT OF COMMITMENTS IN LETTER, DATED JUNE 20, 2017, FOR RESOLUTION OF ACHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSUES - LASALLE COUNTY STATION - UNITS 1 AND 2

Dear Mr. Hanson:

(b)(S) Deliberative Privilege

B. Hanson . 2.

(b)(S) Deliberative Privilege Sincerely, Cynthia D. Pederson Regional Administrator Docket Nos. 50-373, 50-374 License Nos. NPF-11 , NPF-18 cc: State of Illinois

ML 17 OFC NAME Kl ambert:jc RSkokowski KStoedter MJeffers Plouden KO'brien CPederson DATE I /17 I /17 I /17 I /17 I /17 I /17 I /17 Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

ACKNOWLEDGEMENT OF COMMITMENTS IN LETTER, DATED JUNE 20, 2017, FOR RESOLUTION OF ACHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSUES - LASALLE COUNTY STATION - UNITS 1 AND 2

Dear Mr. Hanson:

(b)(S) Deliberative Privilege

(b)(S) Deliberative Privilege Sincerely, Cynthia D. Pederson Regional Admin istrator Docket Nos. 50-373, 50-374 License Nos. NPF-11, NPF-18 cc: State of Illinois Distribution:

Jeremy Bowen RidsNrrDorllpl3 RidsNrrPMLaSalle RidsNrrDirslrib Resource Michael Johnson William Dean Patricia Holahan

Cynthia Pederson Darrell Roberts Ken O'Brien Mohammed Shuaibi Juan Peralta Mark Marshfield Lauren Casey Richard Skokowski Ken Lambert Allan Barker Harral Logaras Viktoria Mitlying Prema Chandrathil Concurrence; Lambert I Skokowski / Stoedter/ Jeffers/ Louden/ O'Brien/ Pederson

EA-17-XXX Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

l(b)(5) Deliberative Pri vilege ~ LASALLE COUNTY STATION

Dear Mr. Hanson:

(b)(S) Deliberative Privilege

(b)(S) Deliberative Privilege Sincerely, Regional Administrator Docket Nos. 50-373

License Nos. NPF-11 cc: State of Illinois Distribution:

Jeremy Bowen RidsNrrDorlLpl3 RidsNrrPMLaSalle RidsNrrDirslrib Resource Michael Johnson William Dean Patricia Holahan Cynthia Pederson Darrell Roberts Ken O'Brien Mohammed Shuaibi Juan Peralta Mark Marshfield Lauren Casey Richard Skokowski Ken Lambert Allan Barker Harral Logaras Viktoria Mitlying Prema Chandrathil Concurrence; Lambert I Jeffers I O'Brien / NRR: Dean/ OE: Holahan / OGC: Kirkwood/

Skokowski / Pederson

EA-[YY]-[XXX]

Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

{Insert [TITLE OF ORDER] or "CONFIRMATORY ORDER," "ORDER MODIFYING LICENSE," "ORDER SUSPENDING LICENSE," or "DEMAND FOR INFORMATION," etc.} {If applicable, add "AND INVESTIGATION REPORT ([X-XXXX-XXX])"} {Also, add " - "[FACILITY or PLANT NAME] if applicable}

Dear Mr. Hanson:

(b)(S) Deliberative Privilege Last Revised or Reviewed: March 2017

(b)(S) Deliberative Privilege Sincerely, Director (Regional Administrator)

Office of Enforcement (Region [#])

Docket Nos. 50-373; 50-374 License Nos. NPF-11 ; NPF-18 Enclosure(s): As Stated {For a OF/ being issued to an individual, include copies of the following documents: (1) 10 CFR 50.5 (or equivalent regulation, e.g., 30.10); (2) 10 CFR 2.204; and (3) The NRG Enforcement Policy.}

cc: {If applicable, include the title of the individual employee that is the subject of the action.}

Last Revised or Reviewed: March 2017

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. - - -

(LICENSEE) License No. - - -

(Facility Name) EA-YY-XXX (b)(S) Deliberative Privilege Last Revised or Reviewed - May 2013

(b)(S) Deliberative Privilege 4

Last Revised or Reviewed - May 2013

(b)(S) Deliberative Privilege 5

Last Revised or Reviewed - May 2013

(b)(S) Deliberative Privilege FOR THE NUCLEAR REGULATORY COMMISSION 6

Last Revised or Reviewed - May 2013

Deputy Executive Director for- - - -

Dated this _ day of (Month), 20(XX) 7 Last Revised or Reviewed - May 2013

Mr. Bryan C. Hanson Senior VP , Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville , IL 60555

SUBJECT:

ACKNOWLEDGEMENT OF COMMITMENTS IN LETTER, DATED JUNE 20, 2017, FOR RESOLUTION OF ACHOR DARLING DOUBLE DISC GATE VALVE PART 21 ISSUES-LASALLE COUNTY STATION (b)(S) Deliberative Privilege Sincerely,

Cynthia D. Pederson Regional Administrator Docket Nos. 50-373 License Nos. NPF-11 cc: Distribution via LISTSERV DISTRIBUTION:

RidsNrrDorlLpl3 RidsN rrPMLaSalle RidsNrrDirslrib Resource Michael Johnson William Dean Jeremy Bowen Cynthia Pederson Darrell Roberts Ken O'Brien Mohammed Shuaibi Juan Peralta Mark Marshfield Lauren Casey Richard Skokowski Ken Lambert Allan Barker Harral Logaras Viktoria Mitlying Prema Chandrathil DRPIII DRSIII ROPassessment. Resource@nrc.gov Concurrence: Lambert I Jeffers I Stoedter I O'Brien / Skokowski / Pederson

From: Benjamin 1amie To: Rodric:uez Lionel; Dunlop Andrew; Phillips Charles: Farnan Michael Cc: leffers Mark: Stoedter Karla: Skokowski. Richard

Subject:

RE: Does this example fit?

Date: Thursday. June 08, 2017 2:34:14 PM (b)(S) Deliberative Privilege

From: Hilton Nick To: Skr owski Rjcbacd Subject : RE (b)(S) Deliberative Privilege Date: Thursday, June 15, 2017 2:54:39 PM Is there a set of briefing slides (even draft) on this?

From: Skokowski, Richard Sent: Thursday, Ju ne 15, 2017 2:09 PM To: Hilton, Nick <N ick.Hilton@nrc.gov>; Pera lta, Juan <Juan .Pe ralta@ nrc.gov>; Ped uzzi, Fra ncis

<Francis.Ped uzzi@nrc.gov>

Cc: O'Brien, Kenneth <Kenneth .O'Brien@nrc.gov>; Jeffers, M ark <Ma rk .Jeffers@nrc.gov>; Benjamin, Jamie <Jamie.Benjam in@nrc.gov>; Heck, Ja red <Ja red.Heck@ nrc.gov>; La m bert, Kenn eth

Subject:

!(b)(S) Deliberative Privilege Good afternoon, (b)(S) Deliberative Privilege VR Rick

From:

To:

Cc:

Subject:

Da te :

l(b)(S) Deliberative Privilege Jared From: Skokowski, Richard Sent: Thursday, Ju ne 15, 2017 1:09 PM To: Hil ton, Nick <N ick.Hilton@nrc.gov>; Pera lta, Juan <Juan.Pera lta@ nrc.gov>; Ped uzzi, Fra ncis

<Francis.Ped uzzi@nrc.gov>

Cc: O' Brien, Kenn et h <Kenneth.O'Brien@nrc.gov>; Jeffers, Mark <Ma rk.J effers@nrc.gov>; Benjamin, Jamie <Jamie.Benjam in@nrc.gov>; Heck, Ja red <Jared. Heck@nrc.gov>; Lambert, Kenneth

<Kenneth. Lambert@nrc.gov>

Subject1(b)(5) Deliberative Privilege Good afternoon, (b)(S) Deliberative Privilege VR Rick

Simulator Observations On April 26, 2017, the inspectors observed a series of scenarios on the LaSalle Unit 1 simulator. The objective was to observe how many times the high pressure core spray (HPCS) or the reactor core isolation cooling (RCIC) system injection valves, which were susceptible to the Anchor Darling double disc gate valve (ADDDGV) 10 CFR Part 21 issue, might cycle during certain design basis events.

The first observation was a station blackout (SBO) with the HPCS failed . The RCIC system initiated and the injection valve (1 E51-F013) opened and stayed open through the entire observation period which lasted about 22 minutes. Level was stable at about -77 inches and pressure was being controlled using safety-relief valves (SRVs). The inspectors concluded that the RCIC system 1E51-F013 valve would cycle several times during a long term event based on the loss of inventory being caused by opening the SRVs but the a rapid cycling was not observed.

The second observation was an SBO with the RCIC system failed . The observation lasted about 44 minutes. The HPCS injection valve (1 E22-F004) auto opened upon reaching level 2 in the reactor. The Unit Supervisor established a level band at -30 to 50 inches in the wide range and HPCS was manually controlled from that point forward. The operator manually closed the valve three times and opened the valve twice more during the observation. The inspectors concluded that in a long term event the 1E22-F004 valve would open several more times based on the loss of inventory through the SRVs. Due to the ongoing reduction of decay heat as the scenario progressed the time period between opening the SRVs and the time between HPCS injections would increase.

The third observation was a loss of feed and condensate with the RCIC system failed. The observation lasted 29 minutes. The 1E22-F004 auto opened upon reaching level 2 in the reactor. The unit supervisor established a level band of -20 to 50 inches and the operators took manual control of the HPCS system. The 1E22-F004 closed, re-opened and closed again during the observation. In this scenario the control rod drive system (CRD) was operational.

The CRD system injected into the reactor at full capacity, however, at this point in the scenario that was not enough to maintain inventory and so that was why the 1 E22-F004 was opened the second time. The inspectors concluded that the 1E22-F004 would cycle more times but that the number of cycles would be less than the above scenario based on the additional inventory added from the CRD system. The CRD system was nonsafety-related .

The inspectors compared the above observations with the actual number of valve cycles during an actual dual unit loss of offsite power event that occurred at LaSalle in 2013. The 1 and 2E22-F004 valves each cycled once, and the 1E51-F013 valve cycled 34 times in just under 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />. The 2E51-F013 was not susceptible to the ADDDGV 10 CFR Part 21 issue. The inspectors also compared these numbers to the number of strokes of the 2E22-F004 valve before it was ultimately determined to have failed during the 2RF17 refueling outage. The 2E22-F004 was stroked five times up to and during the rotation check on the valve that was

intended to ensure the valve stem and disc were not separated. The valve was also stroked an additional four times before the valve disc was verified to have separated from the stem. These additional four strokes were part of a HPCS rela lo ic test and would not have verified that the b 5 Deliberative Privile e (b)(S) Deliberative Privilege Assessment of Extent of Cond ition The inspectors reviewed the licensee's evaluation of the 10 CFR Part 21 notification from Flowserve and the licensee's operability evaluation and assessed how the licensee addressed the extent of condition. The inspectors concluded that the licensee's actions to address the extent of condition were not extensive enough to address the scope of the problem.

The licensee determined that there were 17 valves susceptible to the Flowserve 10 CFR Part 21 issue. One valve, the 2E22-F004, had been repaired after its failure in February 2017. The repaired valve had newer stronger stem and pin material, was pre-torqued to 7000 ft-lbs, and had new thread material installed inside the wedge.

The licensee determined the other 16 valves were operable which was documented in Operability Determination 17-02. The operabil ity determination had three compensatory actions upon which the licensee clearly stated were not necessary for operability. The compensatory actions were:

For valves that are cycled during scheduled surveillances perform rotation checks;

Valves shall not be cycled (stroked) unnecessarily unless required for emergency response . Eng ineering Shall approve any additional maintenance activities that required cycling of the affected valves; and

For transient events that require the sustained operation of the RCIC system, Operations should adjust RCIC flow to limit cycling of the RCIC injection valve 1E51 -5013.

These compensatory measures were issued in Standing Order S 17-05, Revision 0, effective date May 1, 2017.

The licensee had one corrective action. That action was to schedule and implement the repair of the following valves no later than the next unit refueling outage: 1E22-F004, 1(2)E22-F012, 1(2)E22-F015, 1E51-F013, 1(2) E51-F008, 1(2)E51-F063, 1(2)G33-F001, and 1(2)G33-F004.

l(b)(S) Deliberative Privilege

l(b)(S) Deliberative Privilege The licensee concluded operability was based on three things. First, a functional degradation was likely to be preceded by degradation in the stem rotation and diagnostics and none were observed. Second, there was available margin between, from when an observation of a degradation in the stem rotation and diagnostics, and the onset of loss of function. Third, the margins described in the first two were sufficient to ensure ongoing operability.

The inspectors concluded that, based on the information below, the stem rotational checks were insufficient to support that the valve stems on the potentially affected valves were not rotating.

The inspectors interviewed several maintenance personnel that were involved in performing the stem rotational check on the Unit 2 HPCS injection valve 2E22-F004 during the refueling outage in February 2017. The valve is on a platform. There was only one individual on the platform for the measurement and that individual was a traveler from another site and was not available for interview. The other maintenance personnel had been involved with other stem rotational checks and described the method used on other valves . The method used to measure stem rotation was described as that the stem and the gland follower were match marked. Then a "trip ticket," which was best described as a three inch by five inch cardboard card, was placed against the stem and marked where the stem was match marked. When the stem began to move the individual responsible for the measurement then marked the "trip ticket" where they best thought the stem had rotated to if at all. Licensee personnel stated that most of the stem rotation would occur at the beginning of stem movement. The marks on the "trip ticket" were then compared to a compass type wheel that was in the work package. Th is was how the number of degrees of stem rotation was determined.

The inspectors reviewed Work Order (WO) 01814252-01 , "Perform Stem Lube and Minimal Stem Rotation Check," performed on February 8, 2017, for 2E22-F004. The results listed on the WO in Step 6.9 was that the rotation was less than ten degrees. The inspectors determined that the stem diameter was 2.25 inches. The inspectors asked the licensee what the diameter of the compass wheel was and the licensee responded that the diameter of the wheel was 2.375 inches. The diameter of the shaft in comparison to the diameter of the compass wheel could result in a reading that would be more or less conservative . In this case with the shaft diameter less that the diameter of the wheel the read ing wou ld be less conservative. When added to the fact that the marking on the compass wheel in the work package was more a scribble than a finely drawn line it was likely that the actual result was possibly more than ten degrees.

The inspectors also reviewed WO 01664607-01, "Visual Verification of Minimal Stem Rotation for 2E22-F004," dated February 5, 2015. This work order stated in the work performed section of the document, "observed approx. 5-10 degrees of stem rotation from the backseat to seated position on the valve." In Step 6.6 of the WO the amount of stem rotation was documented as approxi mately ten degrees. In WO 01615737-01 , "Borescope MTR, EQ Inspection & Votes

2E22-F004 In L2R15," on page 32 of 33 of an attached procedure MA-AA-723-300, "Diagnostic Testing Of Motor Operated Valves," dated February 5, 2015, it was written "less than 5° stem rotation observed." So for the same test, on the same day, there were three different amounts of rotation documented in two different work packages on 2E22-F004.

In addition to the lack of accuracy associated with the stem rotation measurement method, the licensee stated the following on page 6 of Attachment A of Op Eval 17-002, Revision 0:

Anomalies were noted in one of the earlier diagnostic test traces for 2E22-F015 (Attachment 2). The most recent diagnostic testing of the 2E22-F015 was in 2015 and review of the trace from 2015 shows that the integrity of the stem to disc connection has not been compromised. In addition to this, the previous stem rotation check showed 1 degree of rotation. During re-review of the traces some anomalies were noted and considered potentially attributed to using a "D" clamp vs a QSS for the testing . To further understand the anomalies, additional independent assessments of all 2E22-F015 traces were performed. These assessments indicated that there is variation in seating and unseating performance and that evaluation of the changes in pullout times could represent potential stem rotation between 25 to 62 degrees. This is based on the 0.413 seconds variation times the stem speed seen in Attachment 2. A conservative interpretation is that the rotations indicate the potential for stem-to wedge unthreading during opening, and re-threading during closure. Fu rther, based on the variability between traces, the rotation does not appear every time which may account for any acceptable stem rotation measurements.

As can be seen in the paragraph above an acceptable stem rotation check may still not indicate that the valve stem was not capable of rotating.

In addition, the Anchor Darling valve in the Browns Ferry event failed because a disc retaining clip fell off and blocked the closure of the valve when the wedge pin was broken. The failure of the disc retaining pin at Browns Ferry was identified because of a failed local leak rate test.

When the valve was disassembled the stem was found to be tightly torqued into the wedge.

The inspectors questioned whether a failure similar to the Browns Ferry event would have been evident from a diagnostic trace. The licensee stated that there would be a different seating profile on the diagnostic test if the disc retaining clip fell into the bottom of the valve body. So the inspectors concluded that a failure of the disc retaining pin may or may not be observable in a stem rotation check because the stem would rotate until firmly torqued into the wedge , and would most likely be observable in a diagnostic test but at that point there would be no margin to failu re on the applicable valves that were designated as containment isolation valves. At LaSalle, all the valves associated with the 10 CFR Part 21, with exception of the HPCS system valves, had disc retaining clips. The valves for which th is type of failure would be most significant were containment isolation valves. This included:

1(2) E51-F008, Unit 1/2 RCIC outboard steam supply isolation valves;

1(2) E51-F063, Unit 1/2 RCIC inboard steam supply isolation valves; 1(2) E22-F015, Unit 1/2 HPCS pump suction isolation valves; 1(2) G33-F001 , Unit 1/2 RWCU inboard isolation valves; and 1(2) G33-F001 , Unit 1/2 RWCU outboard isolation valves.

Finally, because in hindsight the 2E22-F004 had a diagnostic anomaly and stem rotation indication along with some extra valve cycles prior to the valve failure , the licensee concluded that there would be margin to failure when either stem rotation and/or a diagnostic test indicated that valve degradation had started. The inspectors concluded that although there may be margin to failure from the time the valve begins to degrade the exact amount of margin cannot be assumed to be the same or less conservative for all valves as the margin that existed prior to the failure of the 2E22-F004.

Documents reviewed:

VPF 3173-269, "12"-900# Motor control Valve Outline," Revision 5 W9223690, "10"-900# Weld Ends Carbon Steel Double Disc Gate Valve For Limitorque SB-2-80 Actuator," Revision H WO 01615737, "Borescope MTR, EQ Inspect & Votes 2E22-F004 In L2R15 ," February 5, 2015 WO 01664607-01, "Visual Verification of Minimal Stem Rotation for 2E22-F004," February 5, 2015 AR 01484815, "Flowseerve 10CFR21, Valve Wedge Pin Failure -Anchor Darling," March 7, 2013 LS-AA-115, "Operating Experience Program," Revision 17 CC-AA-309-1012, "10 CFR Part 21 Technical Evaluations," Revision 3 Nuclear Event Report NC-017-008-Y, "LaSalle 2E22-F004 HPCS MOV Stem Disc Separation,"

Revision O

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION OFFICE OF NEW REACTORS WASHINGTON , DC 20555 (b)(5) Deliberati ve Privilege June XX, 2017 NRC INFORMATION NOTICE 2017-XX: ANCHOR/DARLING DOUBLE DI WEDGE PIN AND STEM-DISC SEPARATION FAILURES ADDRESSEES (b)(5) Deliberati ve Privilege ML17153A053

IN 2017-XX Page 2 of 6 (b)(5) Deliberative Privilege

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!! Comment I Organization I Comment Response IIN ,..,hPr I 11 (b)(5) Deliberative Privilege

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Threaded and Pinned Connection Capability o Stem/Wedge Thread Condition Unknown o Negatives

U2 would pass given the methodology used to demonstrate U1 is operable

Methodology is Wrong?

Inputs are Wrong?

Unknown Failure Mechanism?

Analysis methodology only evaluates static conditions. The real "dynamic" conditions do not apply loads evenly and may overstress threads.

o Positives

U1 has not failed yet

Thread Shear Capabil ity o Thread Engagement Unknown o Stem/Wedge Thread Condition Unknown

Number of Cycles o Motor Brakes o Gear Change

Stem Rotation Checks

Diagnostic Traces

Pretorque of Threaded and Pinned Connection o Inconclusive

Stem Collar Design Capability o Exceeded

DRAFT Talking Points The LaSalle plant was and continues to operate safely. The safety related valves in both U1 and U2 have been repaired during recent plant shutdowns.

The NRC requires plants to have safety systems in place and able to operate during events.

During NRC required routine testing a valve on (the U2 HPCS) safety system failed to open as designed . U2 was already shutdown for a refueling outage and made repairs to the valve.

The NRC conducted a special inspection to review the valve issue. During this inspection the NRC had several discussions with the plant and raised numerous questions about the company's data, analysis and the U1 's system's ability to operate when needed. Ultimately Exelon decided to shut down U1 to repair the valve and have it analyzed further.

The valve on the (HPCS safety system) is required to open to allow water into the reactor during an event. This is one of many(how many??) NRC required safety systems designed to provide water to the reactor.

The NRC will independently???? review the company's analysis of the U1 valve and make its own conclusions publically available via a special inspection report.

The NRC team of inspectors included specialists in XXXXXX. They examined .. and reviewed .. ...

LaSalle Valve Questions Safety Q's Is LaSalle U1 /U2 operating safely? Why?

Why did Exelon shutdown? Was the NRC involved in the decision?

Did LaSalle fix the problem?

What's the problem with the HPCS/Double Disc Gate valves at LaSalle? What does it/system do? Why is it safety related?

Was the plant operating safely before Exelon replaced the valve?

When did the NRC know there was a problem with the valve at LaSalle U2 and U1?

When the NRC discovered the uncertainity with U2 why didn't you just tell U1 to immediately shutdown? Why was the plant allowed to continue operating---industry's lapdog?

Why are you gambling with the public's safety? Isn't this just another example of industry wishes being the top priority and the public's safety being dead last?

LaSalle Detail Q's How was the problem at LaSalle discovered?

This was on a safety system, with all of your inspections focused on safety systems, how did the NRC miss this?

How often is the HPCS safety system inspected?

Obviously the NRC wasn't too concerned about the plant continuing to operate. The U2 SIT started on April 24 and U1 eventually shut down on June 22- ---almost 60 days later. The NRC didn't order the plant to shut down but Exelon eventually shutdown. Can you explain to us what was happening during that time?

For U 1 and U2. How much degradation occurred on the stem? How close was the plant to breaking the stem/valve?

Was this in 2017 by happenstance?

How will this situation be resolved/documented? Will we get a report?

Generic Q's When was the NRC first aware of problems with these types of valves?

How many are affected by this issues? How many these valves are in npp's? Where are the va lves located? How many are on safety systems?

How did every test/analysis miss this huge problem?

If this valve was known to have issues across the industry issue-why did the NRC not do anything about it? What actions did you take?

What is a Part 21 and an Information Notice?

Shouldn't Exelon and the industry have taken action to check these valves?

If there was a Part 21 written in 2013 why wasn't the issue addressed back then? NRC why did you not inspecUfollow up on this issue and only trust the industry?

Which plants are still operating with questionable valves? Why not order them to shut down and replace the ones required for safety?

DRAFT Talking Points The plant is operating safely.

The plant had been operating safely .. ..

The NRC was involved in the decision .... .

During a test the plant identified ....

The plant is required too ...

LaSalle Valve Questions Safety Q's Is LaSalle U1 /U2 operating safely?

Why did Exelon shutdown? Was the NRC involved in the decision?

Did they fix the problem?

What's the problem with these (Anchor Darling Double Disc Gate Valves) valves at LaSalle?

What does it do? Why is it safety related?

ls/was the NRC concerned with U1 operating in the previous condition? Was the plant operating safely before Exelon replaced the valve?

When did the NRC know there was a problem with the LaSalle valve? How cou ld the NRC allowed the plant to operate for so long?

When the NRC discovered the dangerous situation with U2 why didn't you just tell U1 to immediately shutdown? Why did you allow the plant to continue operating---industry's lapdog?

Was Exelon able to prove the safety valve worked for U1? NRC did you agree with their analysis?

Why are you gambling with the publ ic's safety? Isn't this just another example of industry wishes being the top priority and the public's safety being dead last?

LaSalle Detail Q's How was the LaSalle problem identified?

What did the U2 SIT uncover that caused concern with U1?

This was on a safety system, with all of your inspections focused on safety systems, how did the NRC miss this?

How often are these safety systems inspected?

Obviously the NRC wasn't too concerned about the plant continu ing to operate. The U2 SIT started on April 24 and U1 eventually shut down on June 22- ---almost 60 days later. The NRC didn't order the plant to shut down but Exelon eventually shutdown. Can you explain to us what was happening during that time?

What was discussed on June 19 and Jun 20 between Cindy Pederson and Dan Enright? Will those details be made publically available?

For U1 and U2. How much degradation occurred on the stem? How close was the plant to breaking the stem/valve?

It seems this was only caught in 2017 by happenstance?

How will this situation be resolved/documented? Will we get a report?

Generic Q's When was the NRC first aware of problems with these types of valves?

How many of these valves are in npp's? Where are the valves located? How many are on safety systems?

How did every test/analysis miss this huge problem?

If this valve was known to have issues across the industry issue-why did the NRC not do anything about it? What actions did you take?

Shouldn 't Exelon and the industry have taken action to check these valves? Recheck the analysis with Flowserve?

Under what conditions would this safety valve not work?

If there was a Part 21 written in 2013 why wasn 't the issue addressed back then? NRC why did you not inspect/follow up on this issue and only trust the industry?

How many plants does this affect?

Which plants are still operating with questionable valves? Why not order them to shut down and replace the one required for safety?

DRAFT Talking Points The LaSalle plant was and continues to operate safely. The safety related high pressure core spray injection valves in both U1 and U2 have been repaired during recent plant shutdowns.

The NRC requires plants to have safety systems in place and able to operate during events.

During NRC required routine testing a valve on (the U2 HPCS) safety system failed to open as designed. U2 was already shutdown for a refueling outage and made repairs to the valve.

The NRC conducted a special inspection to review the valve issue. During this inspection the NRC had several discussions with the plant and raised numerous questions about the company's data, analysis, and the U1 HPCS system's ability to operate when needed.

Ultimately Exelon decided to shut down U1 to repair the valve and have it analyzed further.

(b)(5) Deliberative Pri vilege to provide water to the reactor.

The NRC will independently review the company's analysis of the U1 valve and make its own conclusions publically available via a special inspection report.

The NRC team of inspectors included specialists in Region Ill and our Office of Nuclear Reactor Regulation in Rockville, MD. They examined and reviewed the historical performance of the HPCS system, previously performed maintenance, modifications made to the HPCS system and the injection valve, and the licensee's use of their corrective action program to correct the previously identified Part 21 issue.

LaSalle Valve Questions Safety Q's Is LaSalle U1/U2 operating safely? Why?

Yes, LaSalle Generating Station is operating safely. Although the NRC's special inspection team identified concerns regarding the HPCS systems' ability to operate following an event, the NRC requires that all nuclear power plants be robustly designed with multiple safety systems.

These safety systems were available to provide water to the reactor if the HPCS system failed to operate. Had the licensee determined the HPCS system was not able to function, the NRC's license for LaSalle allows the plant to operate for an additional 14 days (to provide for repairs) prior to requiring a plant shutdown.

Why did Exelon shutdown? Was the NRC involved in the decision?

Exelon shut down LaSalle Unit 1 to address a potential issue with the operation of a valve on the HPCS system. While the NRC was not involved in Exelon's decision to shut down LaSalle, Unit 1, our special inspection team did develop concerns about the abil ity of the HPCS system to operate if needed. These concerns were shared with the licensee during the inspection and may have played a part in the licensee's decision to shut down.

Did LaSalle fix the problem?

Yes , new parts were installed in the valve during the shutdown . The HPCS system and the injection valve passed all NRC required testing prior to the plant restarting.

What's the problem with the HPCS/Double Disc Gate valves at LaSalle? What does it/system do? Why is it safety related?

(b)(5) Deliberative Privilege The HPCS system provides water to the reactor to ensure the nuclear fuel remains cooled following specific events. Per NRC regulations, the HPCS system is safety related because it is relied upon to remain functional during and following events to ensure the consequences of an event are appropriately mitigated.

Was the plant operating safely before Exelon shut down to repair the valve?

Yes, Exelon was operating LaSalle as required by NRC rules and regulations prior to the shutdown to repair the valve.

When did the NRC know there was a problem with the valve at LaSalle U2 and U1 ?

The NRC became aware of the Unit 2 HPCS valve failure shortly after it occurred in February 2017. As part of our routine refueling outage inspections, the resident inspectors ensured the licensee entered the valve failure into the corrective action program and the licensee repaired/tested the valve in accordance with NRC regulations prior to Unit 2 returning to operation. Exelon's corrective action program provided LaSalle 60 days to evaluate information gathered following the Unit 2 HPCS valve failure. It was during this 60 day timeframe that the NRC identified a similar condition may be present on the Unit 1 HPCS system.

When the NRC discovered the uncertainty with U2 why didn't you just tell U1 to immediately shutdown? Why was the plant allowed to continue operating---industry's lapdog?

The NRC never identified any uncertainty associated with the operation of the Unit 2 HPCS system. Had any uncertainties been identified, the NRC would have responded appropriately.

When the Unit 2 HPCS valve failed during the refueling outage, the HPCS system was not required to be functional. As part of the NRC's routine refueling outage inspections, the resident inspectors ensured the licensee entered the Unit 2 HPCS valve failure into the corrective action program for further evaluation. The inspectors also verified that the licensee repaired and tested the valve in accordance with NRC regulations prior to Unit 2 returning to operation.

Exelon 's corrective action program provided LaSalle 60 days to evaluate information gathered following the Unit 2 HPCS valve failure. It was during this 60 day timeframe that the NRC identified a similar condition may be present on the Unit 1 HPCS system. Once the possibility of a similar condition on Unit 1 was identified, the NRC launched a Special Inspection to evaluate the operation of the Unit 1 HPCS system. During the special inspection, the team developed concerns about the Unit 1 HPCS system's ability to operate when needed. These concerns were discussed with the licensee and may have factored into the licensee's decision to shut down LaSalle Unit 1.

Why are you gambling with the public's safety? Isn't this just another example of industry wishes being the top priority and the public's safety being dead last?

The safety of the public and the plant continue to be the NRC's top priority. No immediate safety issues warranting an expedited plant shut down were identified as part of the special inspection. Had an immediate safety issue been identified, the NRC wou ld have taken action (up to and including the issuance of an order) to ensure the safety issue was addressed in a timely manner.

LaSalle Detail Q's How was the problem at LaSalle discovered?

(Answer if the problem is the Unit 2 valve fai lure) - The failure of the Unit 2 HPCS valve was discovered as part of activities required following system testing. During these activities, the valve failed to open to allow the flow of water. Once the problem was found , actions were taken to fix the valve and return the system to operation. The completion of these actions was verified by the NRC (Answer if the problem was the info discussed in the Part 21) - In February 2013, the NRC and the nuclear industry were informed of a potential manufacturing issue associated with a specific

valve type made by Anchor-Darling. Following this notification, the industry developed a program to monitor the valves for degradation. Although this program was not endorsed by the NRC, the industry (including LaSalle) believed this program would detect valve degradation caused by the potential manufacturing issue prior to failure. Information gathered following the Unit 2 HPCS valve failure and during the SIT appear to indicate that the industry's program may not adequately detect degradation prior to failure. The SIT shared this concern with the licensee during the special inspection. In addition, the NRC has shared information regarding the LaSalle Unit 2 HPCS valve failure with the nuclear industry during two public meetings and by issuing Information Notice 2017-03, "Anchor Darling Double Disk Gate Valve Wedge Pin and Stem-Disc Separation Fai lures," on June 15, 2017.

This was on a safety system, with all of your inspections focused on safety systems, how did the NRC miss this?

The operation of a nuclear power plant is complex and consists of thousands of safety related parts operating when needed. While all licensees are required to perform maintenance and testing on plant equipment, some components/parts do break even though maintenance is performed at appropriate times and testing is completed as required. This was the case with the HPCS valve on LaSalle, Unit 2.

How often is the HPCS safety system inspected/tested?

The HPCS injection valve is tested approximately every 18 to 24 months as part of the licensee's refueling outage activities.

Obviously the NRC wasn't too concerned about the plant continuing to operate. The U2 SIT started on April 24 and U1 eventually shut down on June 22- ---almost 60 days later.

The NRC didn't order the plant to shut down but Exelon eventually shutdown. Can you explain to us what was happening during that time?

If the NRC becomes aware of, or identifies, an immediate safety issue that warrants issuing an order, actions will be taken to address the immediate safety issue. The SIT began on April 24 and concluded on June 9. During this time , the SIT continued to inspect and evaluation information related to the performance, maintenance and testing of both the Unit 1 and Unit 2 HPCS injection valves. No immediate safety issues were identified during the special inspection. While we identified concerns related to the performance of the Unit 1 HPCS injection valve, those concerns did not result in the licensee concluding the Unit 1 HPCS system was inoperable. Had the licensee determined the HPCS system was inoperable at the conclusion of the SIT, the Technical Specifications for LaSalle, Unit 1 would have allowed the plant to continue to operate for an additional 14 days prior to requiring a shut down.

For U1 and U2. How much degradation occurred on the stem? How close was the plant to breaking the stem/valve?

Prema - the condition of the Unit 1 valve is not completely known, but the stem and wedge remained connected when the valve was removed . The licensee also successfully stroked the valve multiple times prior to repairing it ~(b)(5) Deliberative Privilege !

As provided in the licensee's publically available licensee event report and within NRC Information Notice 2017-03, the LaSalle, Unit 2 HPCS injection valve experienced a stem to disk separation. This means that the valve stem was no longer connected to the portion of the valve that moves to allow water to flow to the reactor in response to an event. Once this condition was identified, actions were taken to repair the valve as required by the NRC.

NRC do you know why the valve was not working properly?

Yes, the NRC understands why the LaSalle, Unit 2 HPCS valve did not work properly. These details will be documented in a publically-available inspection report which is scheduled to be issued by July 24, 2017.

Was this in 2017 by happenstance?

l(b)(5) Deliberative Privilege How will this situation be resolved/documented? Will we get a report?

Information regarding the LaSalle, Units 1 and 2 HPCS injection valves will be documented in an NRC Inspection Report. This publically-available report is scheduled to be issued by July 24, 2017.

Generic Q's When was the NRC first aware of problems with these types of valves?

The NRC first became aware of the potential manufacturing issue on Anchor Darling double disk gate valves after receiving an NRC Part 21 notification in February 2013.

How many are affected by this issues? How many these valves are in npp's? Where are the valves located? How many are on safety systems?

We are currently working with the industry to better clarify how many plants are affected by the issue discussed in the Part 21 notification including the number of valves and where they are located. The NRC plans to obtain this information as part of a June 29, 2017, public meeting.

Following this meeting, the NRC will thoroughly evaluate the information provided and determine any additional actions up to, and including, issuing orders.

How did every test/analysis miss this huge problem?

The operation of a nuclear power plant is complex and consists of thousands of safety related parts operating when needed. While all licensees are requ ired to perform maintenance and testing on plant equ ipment, some components/parts do break even though maintenance is performed at appropriate times and testing is completed as required . This was the case with the LaSalle, Unit 2 HPCS valve. Following the Part 21 notification, the industry developed a program to monitor the potentially impacted valves for degradation. Although this program was not endorsed by the NRC, the industry (including LaSalle) believed this program would detect valve degradation caused by the potential manufacturing issue prior to failure.

Information gathered following the Unit 2 HPCS valve failure and during the SIT appear to indicate that the industry's program may not adequately detect valve degradation prior to failure.

The SIT shared this concern with the licensee during the special inspection. In addition, the NRC has shared information regarding the LaSalle Unit 2 HPCS valve failure with the nuclear industry during two publ ic meetings and by issuing Information Notice 2017-03, "Anchor Darling Double Disk Gate Valve Wedge Pin and Stem-Disc Separation Failures," on June 15, 2017.

If this valve was known to have issues across the industry issue-why did the NRC not do anything about it? What actions did you take?

This valve was not (and is not) known to have issues across the industry. The purpose of the Part 21 notification was to notify the NRC and the industry of a potential manufacturing issue.

The NRC requires its licensees to evaluate this information as part of their corrective action program and determine if the manufacturing issue exists at their plant. If a licensee determines the manufacturing issue exists, NRC regulations require that the issue be corrected commensurate with the safety significance.

What is a Part 21 and an Information Notice?

The term, Part 21 , refers to the specific part in Title 1O of the Code of Regulations that requires firms constructing, owning, operating or supplying components to any facility or activity regulated by the NRC to immediately notify the agency of any facility, activity or basic component which fails to meet NRC requirements or contains defects which could create a substantial safety hazard.

Information notices communicate operating or analytical experience to the nuclear industry.

Information notices may also communicate the results of recently completed research. The industry is expected to review the information for applicability and consider appropriate actions to avoid similar problems.

Shouldn't Exelon and the industry have taken action to check these valves?

l(b)(5) Deliberati ve Privilege

If there was a Part 21 written in 2013 why wasn't the issue addressed back then? NRC why did you not inspect/follow up on this issue and only trust the industry?

The Part 21 notification communicated the possibility of a potential issue. Each licensee needed to perform an additional review of the information to determine whether this potential issue existed at each individual plant. Several licensees have inspected their susceptible valves and completed the necessary repairs. Other licensees chose to implement the industry's monitoring program in an effort to assess the valve's condition and plan for future replacement.

These actions appeared reasonable prior to the February 2017 LaSalle, Unit 2 HPCS valve failure. Once the SIT developed concerns about the reasonableness of the monitoring program, the NRC began sharing this information with the industry and determining the need for additional regulatory action. These additional regulatory actions remain under review.

Which plants are still operating with questionable valves? Why not order them to shut down and replace the ones required for safety?

The NRC has not determined that any plant is operating with questionable valves . If this had occurred, action would have been taken to address the safety issues. If the NRC becomes aware that a plant is continuing to operate with questionable valves, we will consider further regulatory action, up to and including the issuance of a shutdown order, to ensure plant safety is maintained.

LaSalle HPCS Valve Talking Points for Midwest CNO (Hanson) and VP Midwest Ops (Enright)

(b)(5) Deliberati ve Privilege

Problem

ThP. L;:iS;:ille Snecial lnsnection was comoleted on June 9th. ICb)(5) Deliberati ve Privilege I (b)(5) Deliberative Privilege

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LaSalle SIT Anchor Darling Double Disc Gate Valve Part 21 Position Paper

he most likely failure mechanism is un ce ain an canno e pre 1c e o any reasona e egree of confidence. Based upon the team's detailed review of the valve design, operational history, and operating experience failure could happen on the next valve stroke, next several valve strokes.

Special Inspection Team's Identified Inadequacies for Unit 1 HPCS Operability

1. Valve has been cycled numerous times since it was replaced in 1987 at closed thrust stem conditions that would have expected to have relaxed any existing pre-torque , broken the wedge pin, plastically deformed the wedge threads and loosening the stem to wedge joint from axial loading, and deformed/damaged/broken wedge threads from torsional rotation.

There is no substantial difference in the failed Unit 2 HPCS operating and stem loading history compared to the in-service Unit 1 HPCS injection valve. (Attachment 1 - detailed information that supports this assessment)

2. Historic MOV traces have been proven to be unreliable in detecting stem to wedge thread degradation based upon the team's review of the Unit 2 HPCS injection valve traces.

(Attachment 2 - detailed information that supports this assessment)

3. MOV stem rotation checks have been proven to be an unreliable method in detecting stem to wedge thread degradation. This assessment was based upon the team's review of the Unit 2 HPCS injection valve stem diagnostics, method inaccuracy, method being performed in only one direction for just of the beginning of the stroke , lack of historical information, and based upon the licensee's MPR failure analysis report that concludes degradation could have been occurring with minimum rotation (i.e. less than 5 degrees). (Attachment 3 -

detailed information that supports this assessment)

4. Industry Operating Experience (specifically LaSalle Unit 2 HPC injection valve, Columbia HPCS injection valve, Duke small valves) confirms that for high thrust applications a broken pin and wedge th read degradation including failure can be expected. (Attachment 4 -

detailed information that supports this assessment)

(b)(5) Deliberative Privilege

Attachment 1. Unit 1 HPCS injection valve number of cycles and cycle loading compared to Unit 2 HPCS injection valve

of cycles roughly of the same The information available on the number of valve stroke cycles is readily available only for the last nine refuel ing outages for each unit. The number of valve cycles for nine outages for U1 is 93 cycles, and the average is 10.333 cycles per outage. Extrapolating this information to account for five additional refueling outages (assumed outages since new valve stem installation in 1987) the total number of cycles would increase to 145 cycles . This total number of cycles does not account for one known thermal cycle (actual system demand). If it is assumed that the thermal cycle on ly cycled the valve once, the total cycles for U1 would increase to 146 cycles. This number does not include cycles during a long outage between 1998 and 1999 for which no information is available.

A similar assessment is performed for the U2 valve. The number of valve cycles for nine outages for U2 is 86 cycles, and the average cycles per outage is 9.555. Extrapolating this information to account for six additional refueling outages (assumed outages since U2 startup) the total number of cycles would increase to 143 cycles . This total number of cycles does not account for two known thermal cycles. If it is assumed that a thermal cycle only cycled the valve once, the total cycles for U2 would increase to 145 cycles. This number does not include cycles during a long outage between 1998 and 1999 for which limited information is available.

Therefore, based on known operational cycles, and extrapolating the data for the unknown history of the valves , it can be assumed that the U1 valve has cycled 1 more time than the U2 valve during operation of the units. However, since U2 was subjected to pre-operational testing, U2 could have more cycles than U1. The licensee, through anecdotal data, assumes the U2 valve was cycled about 40-50 times during pre-operational testing. Using the lower end of the anecdotal data, the U2 valve may have had 39 add itional cycles compared to the U1 va lve .

A similar assessment was performed by the licensee, and they concluded the U2 valve could have as much as 51 additional cycles compared to the U1 valve. The differences come from manipu lation of the data used to develop the averages, and the number of cycles extrapolated for outages for which there is no available information.

It is important to note that the number of valve cycles during an outage could vary from 1-20 cycles. Therefore, the uncertainty of the average can be significant with only nine data points to compare the average to. Applying a rough uncertainty, the final number of total cycles cou ld be off by 7-1 O valve cycles. Using this information, in addition to the fact that only anecdotal data exists for the pre-operational cycles of the U2 valve, the team does not believe that there is a significant difference in the number of cycles between the U1 and the U2 valves.

To summarize, the difference in valve cycles between U1 (si nce 1987) and U2 (since unit startup in about 1984) is not significant, or within the margin of error. The only significant difference in valve cycles between the units can be attributed to pre-operational testing . Since only anecdotal data exists for pre-operational testing , there is no certaint associated with how (b)(5) Deliberative Pri vilege

Stem thrust in closed direction roughly the same for life of plant Both the Unit 1 and Unit 2 HPCS injection valves had roughly the same open and closed torque and thrust loadings over the life of the plant. This was not a surprise since the valves have an identical design and perform the same safety function. Most significantly was that the close thrust loadings had routinely exceeded over 200 kips which had been determine sufficient to slide the collar up and axial deform the wedge threads loosening the joint. Once the joint loosens, subsequent strokes result in torsional loading and additional wedge thread damage. A detailed discussion from the licensee's MPR failure analysis is provided below and demonstrates that routinely exceeding over 200 kips closed stem thrust will lead to valve failure.

From the MPR report.

frhe lab results indicate that the wedge pin failed in torsional shear during closing and that the failure occurred early in the valve's service life.

As mentioned above, the wedge pin is installed after the stem is threaded into the upper wedge and preloaded. As such, the stem threads would be in tension such that the pin would react in a direction to prevent unthreading. During a closing stroke, the stem axial thrust would be reacted by the collar, while the torque is reacted by a combination of friction under the collar and friction in the threads. The pin also contributes to the torque reaction if no clearances exist. If the axial loads exceed the collar slip capacity, then the preload is lost and some of the axial load is transferred to the pin. Without a collar preload, during each subsequent opening and closing stroke, the torque is reacted by the pin and any friction in the threads, while during each closing stroke, the axial load is carried by the pin and collar until movement through the thread clearances is ach ieved.

During the period when the collar and pin are moving through the thread clearances, they share the reaction to the full axial load appl ied by the stem. For a 0.5 inch diameter pin made from A306-60 carbon steel (Reference 3), the pin double shear capacity at 0.6 times the ultimate strength is 17 kips (=0.6 times 72 ksi times twice the pin cross-sectional area) based on a maximum specified tensile strength of 72 ksi (Reference 18). The pin material's ultimate strength is estimated to be about 125 ksi based on the average of the as-found hardness reported in the lab report. Using this estimated ultimate strength, the double shear capacity increases to 29 kips. Combining this with the maximum estimated collar resistance of 130 kips, the total axial capacity is approximately 160 kips, which is still well below the 200+ kip axial loads normally applied. As such, the combined collar and pin axial capacity is not sufficient to prevent further collar axial slip and movement through the thread clearances . In the process, the movement through the clearance ma or may not result in any plastic deformation of the pin.

With collar movement allowing axial motion through the thread clearances, further closing axial loads are reacted by the collar, pin and threads; however, the collar reaction may not occur if the stem experienced any unthreading during prior opening stroke(s). Similarly, the closing torque loads are reacted by collar friction, thread friction , and the wedge pin; however the collar friction may not exist if there was unthreading or collar movement. It is noted that during the closing stroke, the contribution of the friction is directly related to the axial load, which is increasing as the torque is increasing, and these loads ramp up quickly as the valve closes

against the seats. In this dynamic reaction with varying friction conditions , the distribution of the torsional load between the pin and the frictional forces can be indeterminate.

For the nominal 2.25 inch stem diameter at the threads (Reference 3), the pin shear capacities above convert to torsional capacities ranging from 1550 ft-lbs (for minimum specification required ultimate strength) to 2760 ft-lbs (for estimated ultimate strength based on hardness testing). For torque loads typically above 4000 ft-lbs (as shown in Attachment B), the potential to exceed the pin torsional capacity existed without sufficient thread friction developed. Based on the lab results, the pin failure mode is consistent with these loads.

Per Reference 14, the wedge pin margin was calculated for valve 2E22-F004 to be -1 .7%

(negative 1.7%) using the 2015 as-found measured closing thrust and torque of 220,390 lbf and 4,516.6 ft-lbf because these closing loads resulted in the minimum pin failure margin. The applied closing torque was assumed to be shared by the stem-to-wedge threads and the pin only.

A stem-to-wedge thread COF of 0.117 (based on test data) and a pin material ultimate strength of 67.5 ksi were used. However, the calculated margin cannot be relied upon due to previous degradation of the wedge pin (e.g., reduction in pin cross-sectional area) caused by the previous loads, including the undocumented loads experienced b valve 2E22-F004 .

(Historic MOV traces have been proven to be unreliable in detecting stem to wedge thread degradation based upon the team's review of the Unit 2 HPCS injection valve traces.)

Kalsi Engineering was contracted to review the 2015 Unit 2 HPCS injection valve open trace anomaly to determine if a third party would have reached a similar conclusion that the licensee did. Specifically, the anomalies was not indicative of stem to wedge valve degradation and explainable by another mechanism. Kalsi determined that it was appropriate to dispositioned the unlock stem nut anomalies during stem decompression as not an issue related to the part

21. The licensee later provided this letter to the SIT to support their position that a performance deficiency did not exist based upon the licensee's review of historic Unit 2 HPCS injection valve historic traces.

The licensee then changed their opinion part way through the inspection following the team's assessment that the 2015 Unit 2 HPCS injection valve trace (or older traces) did not detect stem to wedge degradation and therefore valve failure could not be foreseen from testing indicators.

Kalsi Engineering was contracted again to provide an assessment if the 2015 anomalies was indicative to stem to wedge threaded connection degradation and, this time , reached a different conclusion based upon the same information.

The team's MOV experts reviewed the data and spoke with Kalsi Engineering and MPR directly several times . The team's conclusion is that there is no evidence, and no adequate explanation that explained how the licensee could reach the conclusion that "pre-hammer blow" data could detect a degraded stem to wedge threaded connection since torque and or thrust is not yet applied to the stem (i.e. worm gear and drive sleeve are not yet connected.) Additionally, the team did not identify any other anomalies in the historic Unit 2 HPCS injection traces that could be correlated to stem to wedge degradation. The team did challenge two Unit 1 HPCS injection valve traces that may be indicative of stem degradation but much like the Unit 2 traces, we just don't know based upon a lack of operating experience.

(b)(5) Deliberative Pri vilege (MOV stem rotation checks have been proven to be an unreliable method in detecting stem to wedge thread degradation.)

The licensee Unit 2 HPCS injection valve stem rotation demonstrates acceptable results . At the time, the acceptance criteria was less than 5-10 degrees of rotation . The Unit 2 HPCS injection valve stem rotationa l results all met this acceptance criteria. The method is not accurate as described below under the best field circumstances.

Stem Rotation Accuracy 2.375" - Compass Diameter (Q 25-0) 2.25" - 1(2)E22-F004 HPCS Injection Valves 1.5" - 1E51-F013 RCIC Injection Valve 1.375" -1(2)E22-F012 HPCS Min . Flow Valves

.21"

~.21

1.1875"

~ .21" 1.125" 270°

~ .21"

0. 75 11

6~ .21"

.6875" Valve Compass 1(2)E22-F004 1E51-F013 1(2)E22-F012 Diameter (in) 2.375 2.25 1.5 1.375 Stem Deflection Stem Rotation Degrees ( 0 )

Length (in) 0.025 1 1 2 2 0.05 2 3 4 4 0 .075 4 4 6 6

0.1 5 5 8 8 0 .125 6 6 10 10 0.15 0.175 0.2 0.225 0.25 0 .275 0.3 0 .325 0.35 0 .375 0.4 0 .425 0.45 0 .475 0.5 The information above demonstrates that for a given stem deflection length, the degrees of rotation are dependent on the stem diameter. The smaller the stem, the more degrees of rotation for a given stem deflection length. The diagram also shows the degrees of stem rotation for a given deflection (.21") representing 10° on the Compass diameter.

The table below provides the stem deflection length required to be measured in order to detect the given degrees of stem rotation. Note that for all stems a deflection length of 1/16"-1/8" would need to be measured to detect 5° of stem rotation.

The licensee explained to the team that they marked the stem and aligned an RWP trip ticket against the stem prior to valve stroke. During the initial part of the valve stroke, the individual performing the test would eyeball any stem rotation and mark it on the trip ticket. The trip ticket and associated two dots would then been compared on a fixed degree wheel to obtain stem rotation degrees. The degree wheel used did not account for different size stems and therefore there measurement was done wrong . The stem rotation check was performed in only one direction based upon the as-found position of the valve and only for the initial part of the stroke.

Additionally, the stem rotation checks have only started recently and are not performed every time the valve is cycled.

The licensee's MPR fa ilure ana lysis report determined that even minimal rotational movement per stroke (e.g., less than 5 degrees) can increase thread wear and degradation.

(Industry Operating Experience (specifically LaSalle Unit 2 HPC injection valve, Columbia HPCS injection valve, Du ke) confirms that for high thrust applications a broken pin and wedge thread degradation including fa ilure can be expected.)

There is no discernable difference between the Unit 2 HPCS injection valve that failed and the Unit 2 HPCS injection valve currently in service regarding valve design, operational history, and torque and thrust loadings. The licensee's failure analysis determined a logical and reasonable explanation for why the Unit 2 valve had failed. Using this operating experience, it is not a matter of "if' but rather, "when the Unit 2 HPCS injection valve will fail inservice.

Columbia's HPCS injection valve wedge pin had failed. The licensee informed the team that the wedge threads had not been evaluated for degradation. The stem threads look good. The Columbia licensee estimated that valve had cycles approximately 200 times since installation which was the same rough estimate for the LaSalle HPCS valves. The Columbia licensee informed the team that he bel ieved the wedge pin had broken a long time ago and identified that the pressfit collar had been pushed up (confirming the design issue for high closed thrust applications). Based upon information from the LaSalle licensee and Columbia licensee, the closed thrust operational conditions was somewhat lower (170-200 kips) as compared to LaSalle 200-230 kips which would explain the difference in the stem to wedge threaded connection.

The 22 + duke valves reviewed as part of the Op Ex did not have any broken pins but did have the press fit collar pushed up. These valves were much smaller 6 inches or smaller as comparted to the 12 inch HPCS injection valves. Based upon the team's review, stem to wedge threaded connection would not have been expected to be degraded or degraded substantially.

Attachment 5 (SIT Created Operability Determination Flow Chart Based upon Inspection)

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LaSalle SIT Anchor Darling Double Disc Gate Valve Part 21 Position Summary DRAFTS

Background

The licensee recently updated their operability evaluation for the valves susceptible to the 2013 Part 21 notification. The updated evaluation alleviated the Special Inspection Team's concerns re arding Licensee's Basis for Operability

1. Using the BWROG topical report as guidance, the licensee is claiming that they are able to detect degradation prior to failure. Specifically, the licensee has performed stem rotation ch ks and diagnostic testing to identify if the function of each valve has been impacted.

2. The licensee revised the wedge pin analysis and calculated the margin to failure of e pin to be approximately +43%. Additionally, the licensee is speculating that the valves cu ntly have full thread engagement and no degradation; therefore, the stem to wedge thread ill not shear.

3. The licensee compared the Unit 1 valve to operating experience provid by Duke. Duke was more aggressive in their resolution to the Part 21 notification and ins cted/replaced the susceptible components within the first outage. The utility dissem d 23+ smaller valves (i.e.,

4"-6") and found no degradation. Additionally, LaSalle reviewe e three year difference in o_perational history of the Unit 1 valve compared to the Unit ailed valve and estimated that the difference in number of cycles performed to be about 20.

S ecial Ins ectlon Team's Identified lnade uacies fo erabilit

1. The wedge pin analysis performed by the licensee sed an inappropriate equation to compute margin to failure. Using the same data and the propriate equation, the SIT calculates that the Unit 1 HPCS injection valve currently has ne tive margin (i.e., -27%) when using the same data. However, the team noted that the c ulational method used by the licensee was extremely sensitive given different frict" factors. Additionally, initial MOVATS testing in 1987 identified the potential for plastic def mation of the pin to have already occurred for the U 1 valve and had alreaqy occurred in the valve.

2. MOV diagnostic data have not been demonstrated to identify whether stem degradatia as occurred or will occur. I.e. the Unit 2 HPCS injection valve that failed showed minimu stem deflection through all stem rotation checks performed and exhibited no trace normality that could be correlated to stem degradation.

3. Full thread e agement with no degradation is an unverified assumption that is not supported by the recent 1lure of the Unit 2 HPCS injection valve.

4. The

ensee could not successfully benchmark the methodology used for operability. I.e. , using th perability bases described above, the Unit 2 HPCS valve that failed would have been eclared operable with positive margin.

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1. What is the evidence that exists that makes us believe there is a reasonable expectation that the unit 1 valve will not meet its safety function?

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