ML19304A126
| ML19304A126 | |
| Person / Time | |
|---|---|
| Issue date: | 10/11/2019 |
| From: | NRC/OCIO |
| To: | |
| References | |
| FOIA, FOIA/PA-2017-0292, NRC-2017-000292 | |
| Download: ML19304A126 (53) | |
Text
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Good Afternoon All.
Listserv Complete! Thanks.
Shawnna Lewfs Aol Vl4CV\\.Lt~b t1Hve Ass:Lstt\\V\\,t Lewis, LaShawnna Friday, September 16, 2016 12:05 PM Clark, Theresa; Wiebe, Joel Keene, Todd; Orf, Tracy; Rohrer, Shiirley; Miller, Ed; Brown, Eva RE: REQUEST: listserv Exelon letter t,{.S. l'-lucLeClY Regt,dCltOYlj C..OVU.VIA.lSS!.011\\,
~,IRJX:./T-'>ORL/LPLl/1-:2 civ>vd. L.PUV-:2 OWF N Ob'-I-H-301. -4 :t5-1.:1,~_9 Ltl.S~C(WV\\,V\\,C(. L ewi..S@V\\,YC, gov From: Clark, Theresa Sent: Friday, September 16, 2016 11:54 AM To: Wiebe, Joel <Joel.Wiebe@nrc.gov>; Lewis, LaShawnna <LaShawnina.Lewis@nrc.gov>
Cc: Keene, Todd <Todd.Keene@nrc.gov>; Orf, Tracy <Tracy.Orf@nrc.gov>; Rohrer, Shirley <Shirley.Rohrer@nrc.gov>;
Miller, Ed <Ed.Miller@nrc.gov>; Brown, Eva <Eva.Brown@nrc.gov>
Subject:
RE: REQUEST: listserv Exelon letter Thanks so much! Yes, it's been distributed internally already.
From: Wiebe, Joel Sent: Friday, September 16, 2016 11:53 AM To: Lewis, LaShawnna <LaShawnna.Lewis@nrc.gov>
Cc: Keene, Todd <Todd.Keene@nrc.gov>; Orf, Tracy <Tracv.Orf@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>;
Rohrer, Shirley <Shirlev.Rohrer@nrc.gov>; Miller, Ed <Ed.Miller@nrc.gov>; Brown, Eva <Eva.Brown@nrc.gov>
Subject:
RE: REQUEST: listserv Exelon letter Lashaw nna, Can you listserve this? I think the rest o f the dispatch will be done upstairs, but you may want to check with Theresa to verify that.
Just listserve it via the normal Byron/Braidwood listserve process.
Joel From: Clark, Theresa Sent: Friday, September 16, 2016 11:39 AM
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To: Miller, Ed <Ed.Miller@nrc.gov>; Wiebe, Joel <Joel.Wiebe@nrc.gov>; Rohrer, Shirley <Shirley.Rohrer@nrc.gov>
Cc: Keene, Todd <Todd.Keene@nrc.gov>; Orf, Tracy <Tracy.Orf@nrc.gov>
Subject:
REQUEST: listserv Exelon letter Importance: High Hi-the letter linked below is now publicly available in ADAMS (public link= ML16243A067). Could you please help us Listserv it as we had discussed earlier in the week? Let me know if you need any more information. Thanks so much!
View ADAMS PS Properties ML16243A067 Open ADAMS P8 Document (09/15/16 Letter to Exelon from Victor McCree.)
Theresa Valentine Clark Executive Technical Assistant (Reactors)
U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0-16E22 2
From:
Clark, Theresa Sent:
Friday, August 26, 2016 10:35 AM To:
Inverso, Tara; Araguas, Christian; Sampson, Michele; Bloomer, Tamara; Jolicoeur, John; Bowen, Jeremy
Subject:
FYI: Byron/Braidwood backfit appeal panel report Hi all! Passing along just for awareness as this report is being discussed in several offices. Vic has not made his decision on this backfit appeal-this is just the panel's report to him. Any questions, let me know. Thanks!
From: Sprogeris, Patricia Sent: Wednesday, August 24, 2016 1:41 PM To: RidsNrrOd Resource <RidsNrrOd.Resource@nrc.gov>; Correia, Richard <Richard.Correia@nrc.gov>; Mizuno, Geary
<Geary.Mizuno@nrc.gov>; Lewis, Robert <Robert.Lewis@nrc.gov>; McGinty, Tim <Tim.McGinty@nrc.gov>; RidsNroOd Resource <RidsNroOd.Resource@nrc.gov>; Johnson, Michael <Michael.Johnson@nrc.gov>; Lubinski, John
<John.Lubinski@nrc.gov>; Mayfield, Michael <Michael.Mayfield@nrc.gov>; Tracy, Glenn <Glenn.Tracy@nrc.gov>;
RidsResOd Resource <RidsResOd.Resource@nrc.gov>; RidsOgcMailCenter Resource
<RidsOgcMailCenter.Resource@nrc.gov>
Subject:
Backfit Appeal Review Panel Findings Associated with Byron & Braidwood Date:
August 24, 2016 From:
Gary M. Holahan K. Steven West Thomas G. Scarbrough Michael A. Spencer Theresa Valentine Clark View ADAMS P8 Properties ML16236Al98 This package, consisting of 5 documents (ML16243A067, ML16236A202, ML16236A208, ML16214A199, and ML16173A311),
is publicly available in ADAMS.
Open ADAMS P8 Package (Backfit Appeal Review Panel Findings (Byron and Braidwood))
Thank you, Patti Patti Sprogeris Assistant to Michael R. Johnson Office of the Executive Director for Operations 301-415-1713 1
From:
Clark, Theresa Sent:
Friday, September 09, 2016 8:38 AM Lewis, Robert To:
Cc:
Holahan, Gary; Rasouli, Houman
Subject:
FYI: 3 DRAFT backfit appeal related documents Good morning, Rob!
Gary and I are working on three pinks that will be needed to complete the Exelon backflt appeal review. They are not final and may need to be significantly revised depending on what Vic's decision is. However, I wanted you to know t hat they are working. Given the expected schedule next week and the draft nature, I propose that you not formally review the pinks, but Gary or I could brief you on the content/decision when appropriate so you are in the loop. Please let me know if you have any questions or concerns. Thanks!
Letter responding to Exelon View ADAMS P8 Properties M L16243A067 Open ADAMS P8 Document (09/XX/16 letter to Exelon from Victor McCree)
Letter responding to NEI (which had sent a letter in support of Exelon)
Yiew ADAMS P8 Properties M L16246A150 Open ADAMS P8 Document {09/XX/16 NEI Comments in Support of Exelon Generat ion Company Second Level Appeal (To: Anthony Pietrangelo, From: Victor Mccree))
Memo to NRR View ADAMS P8 Properties Ml16246A247 Open ADAMS P8 Document (Appeal of Backfit Imposed in Braidwood and Byron Stat ions (To: William Dean, From: Victor Mccree))
Theresa Valentine Clark Executive Technical Assistant (Reactors)
U.S. Nuclear Regulatory Commission Theresa.C1ark@nrc.gov I 301-415-4048 I 0*16E22
From:
Clark, Theresa Sent:
To:
Wednesday, September 14, 2016 1:18 PM Cai, June Cc:
Subject:
Inverso, Tara; Bowen, Jeremy; Bloomer, Tamara; Sampson, Michele; Gartman, Michael RE: Suggestions for safety spotlight topics Here a re two that could be of interest:
Byron/Braidwood backfit appeal (NRR/OEDO) e r on-Responsive Record Theresa Valentine Clark Executive Technical Assistant (Reactors)
U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0 -16E22 From: Cai, June Sent: Wednesday, September 14, 2016 1:14 PM To: Inverso, Tara <Tara.lnverso@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>; Bowen, Jeremy
<Jeremy.Bowen@nrc.gov>; Bloomer, Tamara <Tamara.Bloomer@nrc.gov>; Sampson, Michele
<Michele.Sampson@nrc.gov>; Gartman, Michael <Michael.Gartman@nrc.gov>
Subject:
Suggestions for safety spotlight topics The next Quarterly Strategic Alignment meeting is Nov 1. Please let me know in the next couple of days any suggestions you have for safety spotlight topics.
on-Responsive Record Thanks so much June
' e had three of these meetin 1
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Good morning, all!
Clark, Theresa Thursday, September 15, 2016 9:54 AM Valliere, Nanette; Ruesch, Eric; Castleman, Patrick; Frazier, Alan; Krsek, Robert Lewis, Robert; Rasouli, Houman; Inverso, Tara; Bowen, Jeremy; Holahan, Gary FYI: backfit appeal documents signed This morning, Vic signed the three documents associated with the Byron/Braidwood backfit appeal. They are being processed now, and we expect that they (along with the panel documents referenced within) will be made publicly available in ADAMS later today. Please let me know if you have any questions. Thanks!
Letter responding to Exelon: ML16243A067 All 3 documents are publicly available in ADAMS Letter responding to NEI: ML16246A150 Memo to NRR: Ml16246A247 Theresa Valentine Clark Execut ive Technical Assistant (Reactors)
U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0-16E22
From:
Clark, Theresa Sent:
Thursday, September 15, 2016 10:00 AM To:
Subject:
Holahan, Gary; West, Steven; Scarbrough, Thomas; Spencer, Michael FW: backfit appeal documents signed Good morning, all!
This morning, Vic signed the three documents associated with the Byron/Braidwood backfit appeal. They are being processed now, and we expect that they (along with the panel documents referenced within) will be made publicly available in ADAMS later today. Please let me know if you have any questions. Thanks!
Letter responding to Exelon: ML16243A067 Letter responding to NEI: M L16246A150 Memo to NRR: ML16246A247 Theresa Valentine Clark Executive Technical Assistant (Reactors}
U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301*415-4048 I 0*16E22 All 3 documents are publicly available in ADAMS
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Good morning, all!
Clark, Theresa Thursday, September 15, 2016 9:59 AM Dean, Bill; Evans. Michele; McDermott, Brian; McGinty, Tim; Lubinski, John; Correia, Richard Holahan, Gary; Keene, Todd FYI: backfit appeal documents signed This morning, Vic signed the three documents associated with the Byron/Braidwood backfit appeal. They are being processed now, and we expect that they (along with the panel documents referenced within) will be made publicly available in ADAMS later today. Please let me know if you have any questions. Thanks!
Letter responding to Exelon: ML16243A067 All 3 documents are publicly available in ADAMS Letter responding to NEI: M L16246A150 Memo to NRR: ML16246A247 Theresa Valentine Clark Executive Technical Assistant (Reactors)
U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0 -16E22
From:
Clark, Theresa Sent:
Friday, September 16, 2016 11:01 AM Harrington, Holly To:
Cc:
Subject:
Castelveter, David; Burnell, Scott RE: Current blog draft and Q&A Documents are public! Note t hat I had an error in one ML# I sent before. These links all work:
Letter to Exelon: ML16243A067 Letter to NEI: ML16246A150 Memo to NRR: ML16246A247 Backfit appeal review panel charter: ML16173A311 (link to public ADAMS already functions)
Backfit appeal review panel memo to EDO: ML16236A202 Backfit appeal review panel's detailed report: ML16236A208 RES risk analysis report: ML16214A199
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Hi Rachel!
Clark, Theresa Monday, September 26, 2016 9:43 AM Boyer, Rachel Wertz, Trent; Walker, Sandra Fwd: Appeal of Backfit Imposed in Braidwood and Byron Stations (To: William Dean, From: Victor Mccree)
This memo tasks NRR to provide a plan in 120 days. Can we please ticket it to NRR so it doesn't get lost?
Thanks!
Theresa From: "Banks, Eleasah" <Eleasah.Banks@nrc.gov>
Subject:
Appeal of Backfit Imposed in Braidwood and Byron Stations (To: William Dean, From: Victor McC:ree)
Date: 16 September 2016 08: 17 To: "RidsNrrMaiJCenter Resource" <RidsNrrMailCenter.Resource@nrc.gov>, "RidsOgcMailCenter Resource" <RidsOgcMailCenter.Resource@nrc.gov>, "RidsNroMailCenter Resource"
<RidsN roMail Center. Resource@nrc.gov>, "RidsResPmdaMai l Resource"
<RidsResPmdaMail.Resource@nrc.gov>, "RidsResOd Resource" <RidsResOd.Resource@nrc.gov>,
"RidsNmssOd Resource" <RidsNmssOd.Resource@nrc.gov>, "RidsRgnlMailCenter Resoui*ce"
<RidsRgn I MailCenter.resource@nrc.gov>, "RidsRgn2MailCenter Resource"
<RidsRgn2MailCenter.Resource@nrc.gov>, "RidsRgn3MailCenter Resource"
<RidsRgn3 Mail Center.Resource@nrc.gov>, "RidsRgn4 Mail Center Resource"
<RidsRgn4 MailCenter.Resource@nrc.gov>, "RidsNrrDorlLpl3-2 Resource" <RidsNrrDorlLpl3-2@nrc.gov>,
"RidsNrrPMByron Resource" <RidsNrrPMByronResource.Resource@nrc.gov>, "RidsNrrPMBraidwood Resource" <RidsNrrPMBraidwoodResource.Resource@nrc.gov>, "RidsNrrDss Resource"
<RidsNrrDss.Resource@nrc.gov>, "RidsNrrDe Resource" <RidsNrrDe.Resource@nrc.gov>, "RidsNrrDpr Resource" <RidsNrrDpr.Resource@nrc.gov>, "RidsNrrDorl Resource" <RidsNrrDorl.Resource@nrc.gov>,
"Gam1oe, Alex" <Alex.Garmoe@nrc.gov>, "Keene, Todd" <Todd.Keene@nrc.gov>, "Gody, Tony"
<Tony.Gody@nrc.gov>, "Gendelman, Adam" <Adam.Gendelman@nrc.gov>, "Mizuno, Beth"
<Beth.Mizuno@nrc.gov>, "Correia, Richard" <Richard.Correia@nrc.gov>, "West, Khadijah"
<Khadijah.West@nrc.gov>, "Bailey, Marissa" <Marissa.Bailey@nrc.gov>, "Scarbrough, Thomas"
<Thomas.Scarbrough@nrc.gov>, "Spencer, Michael" <Michael.Spencer@nrc.gov>, "Clark, Theresa"
<Theresa. Clark@nrc.gov>
Date: September 15, 2016 Memorandum To: William M. Dean From: Victor M. Mccree
Subject:
Appeal of Backfit Imposed in Braidwood and Byron Stations (To: William Dean, From: Victor Mccree)
View ADAMS P8 Properties ML16246A247 Open ADAMS P8 Document (Appeal ofBackfit lmpos_~<;I_ in Braidv... *ood and Byron Stations (To: William Dean.
From: Victor Mccree))
2
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Attachments:
Clark, Theresa Tuesday, November 01, 2016 3:29 PM Mccree, Victor; Johnson, Michael; Tracy, Glenn Holahan, Gary FYI: QSAM "safety spotlight" on backfit appeal Safety Spotlight 110316 - Backfit Appeal (TVC).docx Hi there! As you know, I'm on deck for a short presentation on the Byron/Braidwood backfit appeal at Thursday's Quarterly Strategic Alignment Meeting. Attached for your awareness is the 1-pager that I'm planning to use. It has been updated to incorporate feedback from the appeal review panel members, and I plan to give it to June tomorrow as she requested, unless you have any concerns. Thanks and have a great afternoon!
Theresa Valentine Clark Execut ive Technical Assistant (Reactors)
U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0 -4H10
"Safety Spotlight on Backfit Appeal I Quarterly Strategic Alignment Meeting I November 3, 2016 Theresa Clark ln September 2016, the EDO overturned on appeal from Exelon a compliance backfit associated with certain pressuri2er valves at Byron and Braidwood (B/B).
Key Messages Based on the Appeal Panel's Review:
Consistent with the NRC mission and values, it is the staffs right and responsibility to raise safety concerns.
It is the agency's responsibility to employ its processes to evaluate and document the resolution of such concerns.
Evaluation of issues should consider plant licensing basis, industry*wide precedent, and safety significance.
Compliance backfits are Justified far failure to meet known and established" NRC standards at time of approval because of omission or mistake_~_f fact,_f_lOt for new or modified interpretations of what constitutes compliance.
What was the backfit about?
Staff's concern that pressurizer valve failure following water discharge could cause escalation of events to more serious conditions, counter ta plant licensing basis (e.g., ANS-51.1/NlB.2-1973), predicated on several positions:
o ASM E Code qualification for water relief had not been conducted.
o Water relief through an unqualified v.ilve will cause it "to stick fully open."
o The single-failure criterion in the regulations had also not been applied to the valves.
2015 positions differed from those taken for B/B in 2001 and 2004 license amendments.
The staff determined the 2001/2004 positions were in error and that backfitting was justified under the compliance exception (10 CFR S0.109(al(4J(i)). The staff directed the licensee to take action to resolve the non-compliance.
What is (some of) the history?
1968-1972: GDCs define AO Os (normal operation to once in plant life events) and Postulated Accidents 1970+: ANS (and Westinghouse; formulate ANS Conditions I (normal), ll (frequent), Ill (infrequent), IV (accident) and non*
escalation position for transient analysis 1979+: TMI Action Plan item 11.D_l requires "qualification by testing of pressurizer valves; EPRI testing showed that valves did not stick open on water discharge; NRC issued safety evaluations for each plant 1993: Westinghouse (NSAL-93-013) identifies analysis problems {no Part 21 or generic NRC action) 1996+: Licensees update FSAR under 10 CFR 50.59 or request license amendments with varying approaches including reanalysis, PORV upgrades, safety valve crediting, etc.
2001 and 2004: Staff issues B/B amendments, including credit for safety valve water discharge 200S: RIS-05-029 observes that PWR analyses include errors (e.g., non-safety PORVs, un*qualified valves) 2013: Staff determined that a proposed RAI on a B/8 measurement uncertainty uprate was out of scope (not issued) 2015: Staff issued backfit to B/B What happened next?
Staff uphe>ld the backfit on first appeal to NRR.
EDO agreed with Backfit Appeal Review Panel and overturned the backfit on second appeal.
o Positions taken by the N RC staff in the 2015 backfit decision represent new and different staff views on how to address pressurizer safety valve performance following water discharge.
o 2001 and 2004 staff reviews were not in error; though they differ from the current staff approach, they were well-informed and technically founded decisions_
o The 2015 staff position is a well-intentioned and conservative approach that could provide additional safety margin, but not the basis for a compliance backfit.
o Very small risk reduction would be expected from the backfit (separate from defense-in-depth considerations).
NRR is preparing a plan to reassess issues identified in RIS 2005-29 and its draft Revision 1 (due January 2017)..
References:
EDO letter to Exelon on appeal: ML16243AO§l EDO memo to NRR on appeal: ML16246A247 EDO Backfit Appeal Review Panel report: ML15236A204 and ML16236A:?OR (additional references inside)
From:
Clark, Theresa Sent:
To:
Wednesday, November 02, 2016 9:14 AM Cai, June
Subject:
RE: Materials for Thurs Quarterly Strategic Alignment meeting OK. Here's a pre-summary in case you don't hear back from me; I'll send an update if needed. Things are going to be pretty busy for the next few weeks. Thanks.
In the "Safety Spotlight," Theresa Clark provided an oveNiew of the recent EDO decision on the appeal by Exelon of a complicance backfit imposed on Byron and Braidwood in October 2015. The backfit related t o t he ability of certain pressurizer valves to reseat properly after discharging water in certain scenarios. Theresa shared insights from the EDO decision and Backfit Appeal Review Panel's activities, including t he staff's right and responsibility to raise concerns, the importance of evaluating and documenting the resolution of these concerns, and the standard used in the EDO decision for deciding whether a compliance backfit was appropriate.
Staff work is ongoing to develop a plan to assess generically the technical issues ident ified in the backfit, as well as to evaluate guidance and t raining on backfitting as part of an EDO tasking to the Committee to Review Generic Requirements. Additional references are linked in the handout Theresa provided.
From: Cai, June Sent: Wednesday, November 02, 2016 7:43 AM To: Clark, Theresa <Theresa.Clark@nrc.gov>
Subject:
RE: Materials for Thurs Quarterly Strategic Alignment meeting Great. thanks so much.
Yes, I actually do need one other thing...
Within a day or two after the meeting, could you please send me a short summary of your presentation for the meeting summary? The summaries are high level, so just about a short paragraph.
That would be very helpful.
Thanks again June From: Clark, Theresa Sent: Wednesday, November 02, 2016 7:21 AM To: Cai, June <June.Cai@nrc.gov>
Subject:
RE: Materials forThurs Quart erly Strategic Alignment meeting June, attached is my handout for tomorrow's meeting. I already made t he copies. Please let me know if you need anything else. Thanks for coordinating!
Theresa Valentine Clark Execut ive Technical Assistant {Reactors) 1
U.S. Nuclear Regulato~ Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0-4H10 From: Cai, June Sent: Monday, October 31, 2016 7:09 AM To: Clark, Theresa <Theresa.Clark(a:inrc.gov>; Schafer, Maria <Maria.Schofer@nrc.gov>; Allwein, Russell
<Russell.Allwein@nrc.gov>
Subject:
Materia Is for Thurs Quarterly Strategic Alignment meeting For the presentation materials:
- 1) Please send me the electronic version by COB Weds, Nov 2. I will upload on the laptop to show in the roam and the scheduler for remote participants.
- 2) Please bring 50 hard copies to the meeting. Try ta come about 10 minutes early if you can so we can distribute the materials before the meeting starts.
Thanks so much June June Cai Executive Technical Assistant Office of the El<ecutive Director for Operations U.S. Nuclear Regulatory Commission 301-415--1771 june.cai@nrc.gov 2
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Thanks, Michael.
Holahan, Gary Wednesday, August 10, 2016 2:43 PM Spencer, Michael; Scarbrough, Thomas; West, Steven; Clark, Theresa RE: on 1ST issue Hmmm... thinking. My initial thought is that there may be some safe middle ground, in which we don't define programs and requirements but we make sure that our decisions in this case are not misinterpreted.... Sill thinking.
I'm testing some text to add, possibly, to section 5. We should discuss tomorrow.
Gary From: Spencer, Michael Sent: Wednesday, August 10, 2016 2:22 PM To: Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>; Holahan, Gary <Gary.Holahan@nrc.gov>; West, Steven
<Steven.West@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>
Subject:
RE: on 1ST issue
- All, My two, cents: After mulling this over a bit, I think we should refrain from interpreting specific provisions of the ASME Code as part of the backfit appeal. So far, we have focused on the arguments made by the staff and licensee on application of the compliance exception. The original backfit cited ASME requirements generally, but the basis for the compliance exception was the non-escalation criterion. And although we have performed additional research, this has been related to the arguments presented by both sides during two rounds of back-and-forth. Further, having come down on the side of the licensee, we have given the staff an opportunity to respond to our draft preliminary findings to ensure the correctness of our proposed recommendation.
Having looked at the ASME provisions cited by Tom and DE, I can see where they might reasonably be interpreted in different ways. The reference to specific ASME provisions, however, was first raised by DE in an interview conducted for the second-level appeal, and now we are discussing 1ST provisions among the Panel members. The licensee has not had a chance to respond to this, and interpretations of the ASME provisions have the potential to affect numerous licensees. There have been a few occasions in my career where a Board/Commission has made consequential decisions on issues not addressed by the parties. Even though smart people made those decisions, I thought that the decisions would have been better or even different had they been made with input from the parties. Further, our experience has taught me that when interpreting long-standing requirements, it is often necessary to perform substantial research into historical NRC practice.
Given all this, I think discretion is the better part of valor. While we might identify a regulatory issue outside the scope of the backfit that could be explored further, I don't think we should favor a particular interpretation or outcome.
Michael From: Scarbrough, Thomas Sent: Wednesday, August 10, 2016 10:46 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>; West, Steven <Steven.West@nrc.gov>; Clark, Theresa 1
From: Scarbrough, Thomas Sent: Wednesday, August 10, 2016 7:54 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>; West, Steven <Steven.West@nrc.gov>; Clark, Theresa
<Theresa.Clark@nrc.gov>; Spencer, M ichael <Michael.Spencer@nrc.gov>
Subject:
RE: on 1ST issue
- Panel, I reviewed the Byron and Braidwood 1ST Programs, and the applicable ASME OM Code editions and addenda for each plant, with respect to the PSVs and PORVs. I included these documents (and a summary) in the new S:/References/lST Program folder.
To condense the information to a manageable level, I prepared the attached summary of the 1ST provisions for PSVs and PORVs for Byron and Braidwood, and extracted the PSV and PORV requirements from the ASME OM Code 2004 Edition through 2006 Addenda that is referenced in the Byron 1ST Program. The Braidwood 1ST Program references the ASME OM Code 2001 Edition through the 2003 Addenda, which is essentially the same as the ASME OM Code 2004 Edition through 2006 Addenda for the PSV and PORV 1ST requirements. While the PSV and PORV provisions in the Braidwood/Byron 1ST Programs are similar, the Byron 1ST Program includes additional testing provisions for the PORV block valves beyond the Braidwood 1ST Program.
In the summary, I highlighted some relevant provisions from the OM Code related to the responsibility of the Owner to assess the operational readiness of the PSVs and PORVs. For example, in Section 1-8130, "Liquid Service," in Appendix I, valves are required to be tested with the "normal system operating fluid and temperature for which they are designed." In Section 1-1200, "Definitions," in Appendix I, normal system operating conditions (fluid, pressure, temperature) are defined as system fluid, pressure, and temperature during the phase of plant operation for which that system is intended to function.
The term "service conditions" is used for several valve types, but not for PSVs and PORVs, in these OM Code editions and addenda.
I believe that we could clarify the treatment of the PSVs, PORVs, and PORV block valves in the Braidwood/Byron 1ST Programs in light of the UFSAR revision with a call to Exelon. We also might obtain information on the other items that I included at the end of Appendix C. Otherwise, we could identify these items for future staff consideration in the report.
Thanks.
Tom From: Holahan, Gary Sent: Tuesday, August 09, 2016 2:29 PM To: West, Steven <Steven.West@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>; Scarbrough, Thomas
<Thomas.Scarbrough@nrc.gov>; Spencer, Michael <Michael.Spencer@nrc.gov>
Subject:
on 1ST issue
- All, And...
If we meed information from Exelon on the treatment of or discussion of or lack of water discharge in their 1ST program, maybe we should ask them (call them).
Let's also discuss Thursday, 3
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fyi From: Wert, Leonard Holahan, Gary Tuesday, August 02, 2016 1:50 PM West, Steven; Clark. Theresa; Scarbrough, Thomas; Spencer, Michael FW: Exelon Backfit Appeal Panel Preliminary Findings FOR COMMENT - O~O Pre=
decisio11ar - I11teii,al F4RE Use Only D0C_20160802094203.pdf Sent: Tuesday, August 02, 2016 10:35 AM To: Hackett, Edwin Cc: Holahan, Gary; Haney, Catherine; Dudes, Laura
Subject:
RE: Exelon Backfit Appeal Panel Preliminary Findings FOR COMMENT - OUO-Pre-decisional - Internal NRC Use Only-Ed, Thanks, I think the panel is right on target and this break through" vs our typical recent approach on the compliance exception is long overdue. Attached above is a pdf of questions I had just based on a rather brief review of the proposed RIS Rev before we suspended the CRGR review pending the appeal review results.
The draft appeal panel results address my two primary questions. I also like the way the panel characterizes the 2015 staff positions - "Although they represent well-intentioned staff positions that could provide additional safety* margin, they do not provide a basis for a compliance backfit," Nicely stated.
LeM.,,
From: Hackett, Edwin Sent: Tuesday, August 02, 2016 8:14 AM To: Ordaz, Vonna <Vonna.Ordaz@nrc.gov>; Williamson, Edward <Edward.Williamson@nrc.gov>; Wert, Leonard
<Leonard.Wert@nrc.gov>; Moore, Scott <Scott.Moore@nrc.gov>
Cc: West, Steven <Steven.West@nrc.gov>; Mcdermott, Brian <Brian.McDermott@nrc.gov>; Cupidon, Les
<Les.Cupidon@nrc.&QY>; Difrancesco, Nicholas <Nicholas.DiFrancesco@nrc.gov>
Subject:
FW: Exelon Backfit Appeal Panel Preliminary Findings FOR COMMENT - OUO-Pre-decisional - Internal NRC Use Only -
FYI - Preliminary findings from the backfit appeal panel.
Ed From: Holahan, Gary Sent: M onday, August 01, 2016 5:57 PM To: De,an, Bill <Bill.Dean@nrc.gov>; Lubinski, John <John.Lubinski@nrc.gov>; M cginty, Tim <Tim.McGinty@nrc.gov>;
Akstulewicz, Frank <Frank.Akstulewicz.@nrc.gov>; Doane, Margaret <Margaret.Doane@nrc.gov>; Mcdermott, Brian
<Brian.McDermott@nrc.gov>; Bailey, M arissa <Marissa.Bailey@nrc.gov>
Cc: Hackett, Edwin <Edwin.Hackett@nrc.gov>; West, Steven <Steven.West@nrc.gov>; Clark, Theresa
<Theresa.Clark@nrc.gov>; Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>; Spencer, Michael
<Michael.Spencer@nrc.gov>; Evans, Michele <Michele.Evans@nrc.gov>; Williamson, Edward
<Edward.Wi1Eamson@nrc.gov>; Mizuno, Geary <Geary.Mizuno@nrc.gov>; Shuaibi, Mohammed
<Mohammed.Shuaibi@nrc.gov>; M ccree, Victor <Victor.McCree@nrc.gov>; Johnson, M ichael 1
<rvlichael.Johc1.~gn@mc.gov>; Tracy, Glenn <Gler_1n,Irn~y_@nrc.gov>; Gody, Tony <Tony.Gody@nrc.gov>
Subject:
Exelon Backfit Appeal Panel Preliminary Findings FOR COMMENT-QUO-Pre-decisional - Internal NRC Use Only
- All, Consistent with the plan we presented last week, attached are the preliminary findings of the Exelon Backfit Appeal Panel. The Summary from the Preliminary Findings is reproduced below. The preliminary findings were discussed briefly with the OEDO for their awareness.
As indicated in our completion plan, the panel would appreciate any comments on, or additions to: the documents sited; their interpretation and intent; or the understanding of the backfit rule compliance exception.
Comments would be appreciated by August 9, 2016, but can be accepted as last as August 15, 2016. The panel will also be available for discussion any time before August 15, 2016.
Comments will be reflected or acknowledged in the panel's final report and recommendations to the EDO.
The Preliminary Findings document attached is an internal, pre-decisional document at this time. Both Exelon and NEI declined offers for a public meeting on this issue.
Gary... for the panel
-Steve West
-Tom Scarborough
-Michael Spencer
-Theresa Clark In summary:
The NRR 2015 compliance backfit finding (October 9, 2015 letter to Exelon} is predicated on the following positions (emphases added):
"water relief through a valve that is not qualified for water relief will cause that valve to stick in its ful!y open position" "the licensee... has not applied the single-failure assumption" "nor have they provided ASME water qualification documentation for the PSVs... the ASME.., original Overpressure Protection Report... inservice test history... including both water and steam tests" However, none of these positions were "known and established standards of the Commission" in 2001 or 2004 for determining when it was appropriate to assume a failure of PSVs to reseat In fad, they were not "known and established standards of the Commission" in 2005 or 2006 or 2007.
Moreover, two of these positions do not appear to be "established standards of the Commission" at present, since the call for use of the single failure criterion first appears in proposed 2015 draft Revision 1 to RIS 2005-029, and the call for ASME certification first appears in the Exelon compliance backfit. The panel concludes that the standard in place in 2001 and 2004 and at present is simply that the probability of failure of a Pressurizer Safety Valve (PSV) is sufficiently small, based on well-informed staff engineering judgement, and that the use of the word "qualified" or "qualification" implied only a general demonstration of capability, such as in the EPRI testing done in response to TMI Action Plan Item 11.D.1.
The panel concludes that, in 2001 and 2004, the staff was not misinformed nor did it "err" in approving the Byron and Braidwood power uprates... nor was it in error in approving other similar cases (e.g. Beaver Valley in 2006). The 2015 staff positions taken to support the compliance backfit finding represent new and different staff views on how to address potential PSV failures following water discharge. Although they represent well-2
intentioned staff positions that could provide additional safety margin, they do not provide a basis for a compliance backfit.
The panel's findings therefore support the Exelon backf1t appeal.
In addition to the specific finding relating to the backfit appeal, the panel believes it is important to acknowledge that water discharge through a PSV not specifically designed for such service is undesirable and should be minimized or avoided as a matter of conservative engineering and prudent operations. The panel concludes this while fully aware that the event sequence being considered appears to be of little safety significance (the panel has requested RES analysis to confirm this belief). Operator training and emergency procedures to terminate the event before pressurizer filling, as well as the use of power-operated relief valves rather than relying solely on PSVs, are clearly preferred, whether they form the facilities' UFSAR licensing basis or not.
The panel has not (at this time) formed any views on whether a backfit on this topic could be justified as "adequate protection" or "cost justified"; or whether a "forward-fit" staff position is appropriate or not 3
Non-Responsive Record
George <George.Wilson@nrc.gov>
Cc: Mil ler, Ed <Ed.Miller@nrc.gov>
Subject:
RE: EDO Update From: EDO Update [1]
Sent: Friday, September 16, 2016 12:16 PM To: Kreuter, Jane <Jane.Kreuter@nrc.gov>
Subject:
EDO Update q~ U.S.NRC U.niu-d St1t~, ~<l..t-.u ~u..lnmy (Qnun,,,.ion l'rvr<<ti"f Aow fnd 11N E1111ironr,1ent Greetings!
I want to give you a brief update on a recent decision I made regarding the implementation of our backfit process. This process, which is described in 1(
CFR 50.109 (and other analogous processes in our regulations), is meant to ensure that we have an appropriate basis if we need to change the careful, thorough, and technically solid findings we make in licensing nuclear power plants. For example, last week I shared with you some insights about our responsibility to assure adequate protection of public health and safety. This assurance can include the need to impose backfits in accordance with 10 CFR 50.109-as we did, for example, following the accident at Fukushim.
Dai-ichi.
Yesterday, I issued a final decision that supported a licensee appeal and overturned a backfit imposed by the Office of Nuclear Reactor Regulation (NRR). This backfit was issued in 2015 for the Byron and Braidwood nuclear plants in Illinois. Following our Management Directive 8.4 on backfits, I chartered a panel of senior technical and legal staff to consider the facts in this case and recommend a response. This panel reviewed over a hundred documents related to the plants' licensing basis and the history of the technical issues in question and provided a detailed report.
The technical issue in this backfit is discussed in the panel's report. My decision was centered on the regulatory and legal issue of whether the "compliance exception" to the backfit rule's requirement to conduct a backfit analysis was properly applied. In short, the staff needed to show that the initial approvals had been based on a mistake or omission, not that the interpretation of what was acceptable changed over time.
After considering both the pa111el's report and discussions I had with NRR sta1 who contributed to the backfit, I determined that the positions taken in the backfit were new or modified interpretations of what constitutes compliance ir 2
addressing potential pressurizer safety valve failures following water discharge, and did not provide a basis for a compliance backfit.
I recognize that we need to fully understand and disposition the technical concerns that underlie this backfit for the larger group of licensees to which they apply. Therefore, I have referred these technical issues to NRR for further assessment and have asked that a plan be provided within 120 days.
Although I decided to support the licensee's appeal in this case, I am proud to know that our people take seriously the responsibility for assuring public health and safety and are willing to pursue backfits, when appropriate. I encourage the staff to continue to raise issues of potential safety significance, adequate protection, and compliance.
Victor Mccree, EDO 3
From:
Sent:
To:
Cc:
Subject:
Attachments:
- Theresa,
- *** *** *rv:,,,.._..,..,..................,.,.,, *. *--~* ---* 1-.......,ft~,...~.- ~ '"*',,,,~,. *,,...,_,..,.,......._..,. ** *.
Zobler, Marian Monday, September 12, 2016 10:57 AM Clark, Theresa Doane, Margaret; Mayberry, Theresa; Jones, Bradley; Williamson, Edward; Averbach, Andrew RE: URGENT REQUEST: OGC review of letter to Exelon EDO Letter Responding to Exeleon Backfit Appeal OGC.docx OGC has reviewed and is providing an "NLO" on the letter, please note one proposed edit in the attached.
If you lnave any questions, please feel free to contact me.
Marian Marian L. Zobler Associate General Counsel From: Clark, Theresa Sent: Friday, September 09, 2016 3:09 PM To: RidsOgcMailCenter Resource <RidsOgcMailCenter.Resource@nrc.gov>
Cc: Doane, Margaret <Margaret.Doane@nrc.gov>; Jones, Bradley <Bradley.Jones@nrc.gov>; Holahan, Gary
<Gary. Ho la han@nrc.gov>; Mayberry, Theresa <Theresa.Maybe rry@nre.gov>
Subject:
URGENT REQUEST: OGC review of letter to Exelon Importance: High Hi there!
I just spoke wit h Margie, and she said that OGC would be able to review the below-linked letter on short turnaround.
Several people in OGC have already reviewed the underlying staff panel recommendation/report that are referenced in the lett er, so I am hoping that will facilitate things. If we could receive NLO (or comments) by Monday 9/12 t hat would be fantastic. Please let me know if you need any further information.
View ADAMS P8 Properties M L16243A067 Open ADAMS P8 Document (09/XX/16 Letter to Exelon from Victor Mccree) 1
J_ Bradley Fewell Senior Vice President Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 50555
SUBJECT:
RESPONSE TO APPEAL OF BACKFIT IMPOSED ON BRAIDWOOD AND BYRON STATIONS REGARDING COMPLIANCE WITH 10 CFR 50.34(b),
GDC 15, GDC 21, GDC 29, AI\\ID n-lE LICENSII\\IG BASIS
Dear Mr. Fewell:
This letter,, responds to your June 2, 2016, letter (AgeACywide Documents Access and Management System (ADAMS) Accession No. ML16154A254). In Iha! letter, you requested a second-level appeal of the subject backlit, which was issued by the U.S. Nuclear Regulatory Commission (NRG) staff in a letter dated October 9, 2015 (ADAMS Accession No. ML14225A871 ).
In response to your request and in accordance with 1,,.,, Li :i.. N1~cl,;,a1 Pp,qulalo,-.,* c.-"1;,n1;,-,,.-.,_,_
1NRC} Management Directive 8.4, "Management of Facility-specific Backfitting and Information Collection," I appointed several senior NRC staff and managers to constitute a Backlit Appeal Review Panel to review your appeal of the staff's determination that a backlit was necessary at Braidwood Statioo, Units 1 and 2, and Byron Station, Units 1 and 2, as well as the staff's application of the compliance backlit exception provided in Title 1 0 of the Code of Federal Regulations (1 O CFR). Section 50. i 09 (the "Back~t Rule").
The panel undertook a detailed review ol the relevant infonnation at issue, lhal is, information pertinent to the performance of pressurizer safety valves and their treatment during accident analysss which support licensing decisions. The panel also reviewed the compliance exception to the Backlit Rule and re-aftirmed that the compliance exception is intended to adc:lress failures to meet known and established Commission standards because of omission or mistake ot fact.
New or modified interpretatioos of what constitutes compliance therefore do not fall wilhin the exception. The panel documented its review and evaluation ot the technical and legal issues in a report enclosed wilh its memorandum to me. The panel's memorandum and report are publicly available via ADAMS Accession Nos, ML16236A202 and ML16236A208, respectively.
I have reviewed the panel's report, their recommendations. and their response to questions I posed when establishing the panel In addilion. I met with the panel and Office ol Nuclear Reactor Regulation management to assure that this issue has been given thorough, technically sound, and legally well-founded consideration Cornmented [MASlJ: AlteadVdeflned.
J. Fewell Based on my review and discussions, I agree with the panel's conclusion that positions taken by the N RC staff in the 2015 backlit decisioo represent new and difforent staff views on how lo address pressurizer safety valve performance following water discharge. Although these staff positions are conservative approaches that could provide additional safety margin, they do not provide an appropriate basis for a compliance backfil. In the absence of an assumed failure of the pressurizer safety valve to reseat, the concerns articulated in the backlit related to event classilicatron, event escalation, and compliance with 1 o CFR S0.34(b) and General Design Criteria 15, 21, and 29 are no longer at issue.
Docket Nos. STN 50-456. STN 50-457, STN 50-454, and STN 50-455 cc: Listserv Sincerely, Victor M. Mccree Executive D1 rector for Operations
Based on my review and discussions, I agree with the panel's conclusion that positions taken by the NRC staff in the 2015 backlit decision represent new and different staff views on how to address pressurizer safety valve per1ormance lollowing water discharge. Although these staff positions are conservative approaches thal could provide additional salety margin, they do not provide an appropriate basis for a compliance backlit. In the absence of an assumed failure of the pressurizer safety valve to reseat, the concerns articulated in the backlit related to event classification, event escalation, and compliance with 10 CFR 50.34(b) and General Design Criteria 15, 21, and 29 are no longer at issue.
Docket Nos. STN 50-456, STN 50-457, STN 50-454, and STN 50-455 cc: Listserv DISTRIBUTION: OED0-16-00585 Sincerely, Viclor M. Mccree Exec utivc Director for Operations PUBLIC RidsNrrPMBra1dwood RidsNrrMailCenter RidsNrrDss RidsOgcMailCenler RidsNrrOe RidsResMailCenter RidsNrrOpr RidsNroMailCenter RidsNrrOorl RidsRgn3MailCenter AGarmoe, NRA RidsNrrDor1Lpl3*2 TKeene. NRR RidsNrrPMByron AGody, Region 11 ADAMS Accession No.: ML16243A067 AGendclman. OGC GMizurm, OGG RCorreia, RES KSWest, NSIR MBailey, NSIR TScartrough, NRO MASpencer. OGC TClark, OEDO OFFICE OEDO
__ O_G_C ______
O_E_D_0 __,~---0-E_D_O __ _
NAME GHalahan MJohnson VMcCree DATE 08/31/16 091
/16 08131/16 09/
/16 OFFICAL RECORD COPY
From:
Sent:
To:
Subject:
Attachments:
- Panel, Scarbrough, Thomas Wednesday, August 10, 2016 7:54 AM Holahan, Gary; West. Steven; Clark, Theresa; Spencer, Michael RE: on !ST issue Braidwood-Byron PSV-PORV 1ST Provisions (Scarbrough).docx I reviewed the Byron and Braidwood 1ST Programs, and the applicable ASME OM Code editions and addenda for each plant, with respect to the PSVs and PORVs. I included these documents (and a summary) in the new S:/References/lST Program folder.
To condense the information to a manageable level, I prepared the attached summary of the 1ST provisions for PSVs and PORVs for Byron and Braidwood, and extracted the PSV and PORV requirements from the ASME OM Code 2004 Edition through 2006 Addenda that is referenced in the Byron 1ST Program. The Braidwood 1ST Program references the ASME OM Code 2001 Edition through the 2003 Addenda, which is essentially the same as the ASME OM Code 2004 Edition through 2006 Addenda for the PSV and PORV 1ST requirements. While the PSV and PORV provisions in the Braidwood/Byron 1ST Programs are similar, the Byron 1ST Program includes additional testing provisions for the PORV block valves beyond the Braidwood 1ST Program.
In the summary, I highlighted some relevant provisions from the OM Code related to the responsibility of the Owner to assess the operational readiness of the PSVs and PORVs. For example, in Section 1-8130, "Liquid Service," in Appendix I, valves are required to be tested with the "normal system operating fluid and temperature for which they are designed." In Section 1-1200, Definitions," in Appendix I, normal system operating conditions (fluid, pressure, temperature) are defined as system fluid, pressure, and temperature during the phase of plant operation for which that system is intended to function.
The term "service conditions" is used for several valve types, but not for PSVs and PORVs, in these OM Code editions and addenda.
I believe that we could clarify the treatment of the PSVs, PORVs, and PORV block valves in the Braidwood/Byron 1ST Programs in light of the UFSAR revision with a call to Exelon. We also might obtain information on the other items that I included at the end of Appendix C. Otherwise, we could identify these items for future staff consideration in the report.
Thanks.
Tom From: Holahan, Gary Sent: Tuesday, August 09, 2016 2 :29 PM To: West, Steven <Steven.West@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>; Scarbrough, Thomas
<Thomas.Scarbrough@nrc.gov>; Spencer, Michael <Michael.Spencer@nrc.gov>
Subject:
on 1ST issue
- All, And...
1
Braidwood/Byron lnservice Testing Provisions T. Scarbrough August 10,2016 for Pressurizer Safety Valves (PSVs) and Power-Operated Relief Valves (PORVs)
Byron Station, Units 1 and 2 Fourth Ten-Year 1ST Program submitted July 21, 2016, references ASME OM Code 2004 Edition through 2006 Addenda Byron 1ST Program specifies:
PORV *failsafe test closed (cold shutdown); stroke-time exercise open and closed (cold shutdown); and position indication test (2 years).
PORV Block Valve-exercise open and closed (2 years); position indication test (JOG schedule); and OMN-1 open and closed test (JOG schedule).
PSV - Relief Valve Test (5 years); and position indication test (2 years). The 1ST Program references Appendix I to the OM Code for Relief Valve Test.
ASME OM Code 2004 Edition and Oma-2005 and OMb-2006 1ST A-1100 Scope Section 1ST establishes the requirements for preservice and inservice testing and examination of certain components to assess their operational readiness in light-water reactor nuclear power plants. It identifies the components subject to test or examination, responsibilities, methods, intervals, parameters to be measured and evaluated, criteria for evaluating the results, corrective action, personnel qualification, and record keeping. These requirements apply to (a) pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident (b) pressure relief devices that protect systems or portions of systems that perform one or more of these three functions (c) dynamic restraints (snubbers) used in systems that perform one or more of these three functions, or to ensure the integrity of the reactor coolant pressure boundary 1ST A-1500 Owner's Responsibilities The responsibilities of the Owner of the nuclear power plant shall include the following:
(a) determination of the appropriate Code Class for each component of the plant, identification of the system boundaries for each class of components subject to test or examination, and the components exempt from testing or examination requirements (b) design and arrangement of system components to include allowance for adequate access and clearances for conduct of the tests and examinations (c) preparation of plans and schedules (d) preparation of written test and examination instructions and procedures 1
(e) qualification of personnel who perform and evaluate examinations and tests in accordance with the Owner's quality assurance program (f) performance of required tests and examinations (g) recording of required test and examination results that provide a basis for evaluation and facilitate comparison with the results of subsequent tests or examinations (h) evaluation of tests and examination results (i) maintenance of adequate test and examination records such as test and examination data and description of procedures used
{j) retention of all test and examination records for the service lifetime of the component or system (k) documentation of a quality assurance program in accordance with either of the following:
(1JTitle 10, Code of Federal Regulations, Part 50 (2) ASME NQA-1, Parts ti and Ill ISTA-2000 Definitions inservice test: test to assess the operational readiness of a system, structure, or component after first electrical generation by nuclear heat.
operational readiness: the ability of a component to perform its specified functions.
overpressure protection: the means by which components are protected from overpressure by the use of pressure relieving devices or other design provisions as required by the BPV Code, Section Ill, or other applicable construction codes.
valves, active: valves that are required to change obturator position to accomplish a specific function in shutting down a reactor to the safe shutdown condition, maintaining the safe shutdown condition, or mitigating the consequences of an accident.
ISTC-1200 Exemptions Category A and Category B safety and relief valves are excluded from the requirements of ISTC-3700, Valve Position Verification and ISTC-3500, Valve Testing Requirements.
ISTC-1400 Owner's Responsibility In addition to the requirements of ISTA-1500, it is the Owner's responsibility to (a) include in the plant design all necessary instrumentation, test connections, flow instruments, or any other provisions that are required to fully comply with the requirements of this Subsection.
(bJcategorize (see ISTC-1300), and list in the plant records (see ISTC-9000) each valve to be tested in accordance with the rules o1 this Subsection, including Owner-specified acceptance criteria. The Owner shall specify test conditions.
(c) ensure that the application, method, and capability of each nonintrusive technique is qualified.
ISTC-2000 Supplemental Definitions power-operated relief valve (PORV): a power-operated valve that can perform a pressure-relieving function and is remotely actuated by either a signal from a pressure sensing 2
device or a control switch. A power-operated relief valve is not capacity certified under ASME Section Ill overpressure protection requirements.
ISTC-5000 SPECIFIC TESTING REQUIREMENTS ISTC-5100 Power-Operated Valves (POVs)
All valves shall be tested in accordance with the applicable requirements of ISTC-3000, and as identified below, except for power-operated control valves that only have a fail-safe safety function. For power-operated control valves that only have a fail-safe sa1ety function, the requirements for valve stroke-time measurement testing, the associated stroke time test acceptance criteria, and any corrective actions that would result from stroke-time testing need not be met. For these valves, all other applicable requirements of ISTC-3000, and as identified below, shall be met.
ISTC-511 O Power-Operated Relief Valves (PORVs).
Power-operated relief valves shall meet the requirements of ISTC-5100 for the specific Category B valve type and ISTC-5240 for Category C valves.
ISTC-5111 Valve Testing Requirements (a) Testing shall be performed in the following sequence or concurrently. If testing in the following sequence is impractical, it may be performed out of sequence, and a justification shall be documented in the record of tests for each test or in the test plan:
(1 J leakage testing (2) stroke testing (3) position indication testing (b) The pressure-sensing device shall be calibrated in accordance with the Owner's quality assurance program.
ISTC-5112 Leak Testing. Seat tightness of the PORV shall be verified by leak testing in accordance with the requirements of Mandatory Appendix I.
ISTC-5113 Valve Stroke Testing (a) Active valves shall have their stroke times measured when exercised in accordance with ISTC-3500.
(b) The limiting value(s) of full-stroke time of each valve shall be specified by the Owner.
(c) The stroke time of all valves shall be measured to at least the nearest second.
(d) Any abnormality or erratic action shall be recorded (see ISTC-9120) and an evaluation shall be made regarding need for corrective action.
(e) Stroke testing shall be performed during normal operating conditions for temperature and pressure if practicable.
ISTC-5114 Stroke Test Acceptance Criteria.
Test results shall be compared to the reference values established in accordance with ISTC-3300, ISTC-3310, or ISTC-3320.
3
{a) Valves with reference stroke times of greater than 10 sec shall exhibit no more than 125%
change in stroke time when compared to the reference value.
(b) Valves with reference stroke times of less than or equal to 10 sec shall exhibit no more than 150% change in stroke time when compared to the reference value.
(c) Valves that stroke in less than 2 sec may be exempted from 1STC-5114(b). In such cases the maximum limiting stroke time shall be 2 sec.
ISTC-5115 Corrective Action (a) 11 a valve fails the applicable leak test acceptance criteria, to exhibit the required change of obturator position or exceeds the limiting values of full-stroke time (see 1STC-5113(b)], the valve shall be immediately declared inoperable.
(b) Valves with measured stroke times that do not meet the acceptance criteria of lSTC-5114 shall be immediately retested or declared inoperable. If the valve is retested and the second set of data also does not meet the acceptance criteria, the data shall be analyzed within 96 hr to verify that the new stroke time represents acceptable valve operation, or the valve shall be declared inoperable. If the second set of data meets the acceptance criteria, the cause of the initial deviation shall be analyzed and the results documented in the record of tests (see ISTC-9120).
(c) Valves declared inoperable may be repaired, replaced, or the data may be analyzed to determine the cause of the deviation and the valve shown to be operating acceptably.
(d) Valve operability based upon analysis shall have the results of the analysis recorded in the record of tests (see ISTC-9120).
(e) Before returning a repaired or replacement valve to service, a test demonstrating satisfactory operation shall be performed.
ISTC-5240 Safety and Rellef Valves. Sa1ety and relief valves shall meet the inservice test requirements of Mandatory Appendix I.
MANDATORY APPENDIX I lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants 1-1000 GENERAL REQUIREMENTS 1-1100 Applicability The requirements of this Appendix apply to certain pressure relief devices (included in Section Ill of the ASME Boiler and Pressure Vessel Code, hereafter known as the BPV Code).
1-1120 Limitations (a) The requirements of this Appendix recognize differences between the installed operating conditions and the conditions under which a pressure relief device may be tested. For a specific pressure relief device design, if the parameter to be tested is dependent on conditions not specifically addressed by these requirements, the installed operating condition and the test condition shall be comparable, or proven correlations shall be applied.
(b) The requirements of this Appendix apply only to pressure relief devices required for overpressure protection.
(c) The requirements of this Appendix are not intended to demonstrate conformance to design specification requirements.
4
(d) The requirements of this Appendix are not intended to verify or demonstrate all aspects of pressure relief device operation.
1-1200 Definitions normal system operating conditions (fluid, pressure, temperature): system fluid, pressure, and temperature during the phase of plant operation for which that system is intended to function.
overpressure protection: the means by which components are protected from overpressure by the use of pressure relieving devices or other design provisions as required by the BPV Code, Section Ill, or other applicable construction codes.
power-actuated relief valve: a relief valve in which the major relieving device is combined with and controlled by a device requiring an external source of energy.
1-1300 Guiding Principles 1-1310 General (a) Operation and Maintenance Instructions. Complete operation and maintenance instructions shall be available for each device. This Appendix shall be supplemented by these operating and maintenance instructions.
{b) Valve Testing Frequency. A frequency for valve testing is required by this Appendix to provide assurance of the valve operational readiness.
(c) Valve Disassembly. This Appendix does not require valves or accessories to be disassembled or removed from their installed position.
(d) Visual Examination. Visual examinations shall be performed in accordance with the Owner's examination procedures and shall be documented.
(e) Acceptance Criteria. The Owner, based upon system and valve design basics or technical specification, shall establish and document acceptance criteria for tests required by this Appendix.
1-1320 Test Frequencies, Class 1 Pressure Relief Valves (a) 5-Year Test Interval. Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested within each interval; however, a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval. This 20% shall consist of valves that have not been tested during the current 5-year interval, if they exist. The test interval for any individual valve shall not exceed 5 years.
(b) Replacement With Pretested Valves. The Owner may satisfy testing requirements by installing pretested valves to replace valves that have been in service, provided that:
(1) tor replacement of a partial complement of valves, the valves removed from service shall be tested prior to resumption of electric power generation; or (2) for replacement of a full complement of valves, the valves removed from service shall be tested within 12 months of removal from the system.
(c) Requirements for Testing Additional Valves. Additional valves shall be tested in accordance with the following requirements:
(1) For each valve tested for which the as-found set-pressure (first test actuation) exceeds the greater of either the +/-tolerance limit of the Owner-established set-pressure acceptance criteria 5
of 1-131 O(e) or +/-3% of valve nameplate set-pressure, two additional valves shall be tested from the same valve group.
(2) If the as-found set-pressure of any of the additional valves tested in accordance with 1-1320 (c)(1} exceeds the criteria noted therein, then all remaining valves of that same valve group shall be tested.
(3) The Owner shall evaluate the cause and effect of valves that fail to comply with the set-pressure acceptance criteria established in l-1320(c)(1) or the Owner established acceptance criteria for other required tests. such as the acceptance of auxiliary actuating devices, compliance with Owner's seat tightness criteria, etc. Based upon this evaluation, the Owner shall determine the need for testing in addition to the minimum tests specified in l-1320{c) to address any generic concerns that could apply to valves in the same or other valve groups.
1-6000 PRESSURIZED WATER REACTORS (PWR)-INTRODUCTION 1-7000, 1-8000, and 1-9000 define the requirements for performance testing of pressure relief devices for pressurized water reactor nuclear power plants. The valves subject to examinations and tests are categorized. Responsibilities, examination methods, examination techniques, test methods, examination and test frequencies, records, and maintenance requirements are defined. Replacement valves of the same valve group shall be tested to the requirements of 1-7100 and I-7 400. Replacement valves not of the same valve group previously used shall be tested to the requirements of I-7100 and I-7200.
1-7000 PWR PRESSURE RELIEF DEVICE TESTING 1-7100 Testing Before Initial Installation 1-7110 Class 1 Safety Valves. Tests shall be periormed in the following sequence, or manufacturer's production tests may be accepted for 1-711 O(b), (c), and (d), provided the valve passes visual examination in accordance with the Owner's examination procedures:
(a) visual examination (b) set-pressure determination (c) testing of accessories [see 1-731 O(d). (e), and (f)]
(d) determination of compliance with the Owner's seat tightness criteria 1-7120 Class 1 Power Actuated Relief Valves. Tests shall be per1ormed in the following sequence, or manufacturer's production tests may be accepted for l-7120{b), (c), and (d),
provided the valve passes visual examination in accordance with the Owner's examination procedures:
(a) visual examination (b) determination of functional capability (c) testing of accessories (see l-7320(d) and (e)]
(d) determination o1 compliance with the Owner's seat tightness criteria 1-7200 Testing Before Initial Electric Power Generation 1-7210 Class 1 Safety Valves. Within 6 months before initial reactor criticality, each valve shall have its set-pressure verified. Set-pressure verification shall be determined by pressurizing the system up to the valve set-pressure and opening the valve, or the valve may be tested at or below normal system operating pressures with an assist device.
6
1-7220 Class 1 Power-Actuated Relief Valves. After installation, each valve shall be remotely actuated at normal system operating pressure to verify open and close capability.
1-7300 Periodic Testing Periodic testing of all pressure relief devices is required. No maintenance, adjustment, disassembly, or other activity that could aifect "as-found" set-pressure or seat tightness data is permitted before testing. Control ring adjustments are permitted per 1-811 O(g) and l-8120(g).
Test frequencies are specified in 1-1320, J-1330, 1-1340, 1-1350, 1-1360, 1-1370, 1-1380, and 1-1390. When on-line testing is performed to satisfy periodic testing requirements, visual examination may be performed out of sequence.
1-7310 Class 1 Safety Valves. Tests before maintenance or set-pressure adjustment, or both, shall be performed for 1-731 O(a), (b), and (c) in sequence. The remaining shall be performed after maintenance or set-pressure adjustment:
(a) visual examination (b) seat tightness determination, if practicable (c) set-pressure determination (d) determination of operation and electrical characteristics of bellows alarm switch (e) verification of the integrity of the balancing device on balanced valves (f) determination of operation and electrical characteristics of position indicators (g) determination of compliance with Owner's seat tightness criteria 1-7320 Class 1 Power Actuated Relief Valves. Tests before maintenance shall be performed for l-7320(a), (b), and (c) in sequence. The remaining shall be performed after maintenance or set*pressure adjustment:
(a) visual examination (b) seat tightness determination, if practicable (c) set-pressure determination (d) verification of the integrity of the balancing device on balanced valves (e) determination of operation and electrical characteristics of position indicators (f) determination of compliance with the Owner's seat tightness criteria 1-7400 Disposition After Testing or Maintenance 1-7410 Class 1 Safety Valves (a) Valves and accessories that comply with their respective acceptance criteria for the tests specified may be returned to service without further testing.
(b) Valves and accessories that do not comply with their respective acceptance criteria shall be adjusted, refurbished, or replaced in accordance with written procedures. Valves shall be adjusted to meet the acceptance criteria of l-1310(e).
(c) Refurbished equipment shall be subjected to test(s) specified in 1-7310, as applicable. If disassembly includes valve disk (main) components, then valve disk stroke capability shall be verified by mechanical examination or tests.
(d) Valves and accessories that do not comply with their respective criteria, whether the problem is associated with the component, the system, or associated equipment, shall be evaluated to determine the ability of the valve to perform its intended function until the next testing interval or maintenance opportunity. Corrective actions shall be taken, as appropriate, to ensure valve operability.
7
1-7420 Class 1 Power-Actuated Relief Valves (a) Valves and accessories that comply with their respective acceptance criteria for the tests specified may be returned to service without further testing.
(b) Valves that do not comply with their respective acceptance criteria shall be adjusted, refurbished, or replaced in accordance with written procedure. Valves shall be adjusted to meet the acceptance criteria of 1-131 0( e).
(c) Refurbished equipment shall be subjected to test(s) specified in 1-7320, as applicable. If disassembly includes valve disk (main) components, then valve disk stroke capability shall be verified by mechanical examination or tests.
(d) Valves and accessories that do not comply with their respective acceptance criteria, whether the problem is associated with the component, the system, or associated equipment, shall be evaluated to determine the ability of the valve to pertorm its intended function until the next testing interval or maintenance opportunity. Corrective actions shall be taken, as appropriate, to ensure valve operability.
1*8000 PWR TEST METHODS 1-8100 Set-Pressure Testing 1-8110 Steam Service (a) Test Media. Valves designed to operate on steam, including safety valves designed for saturated steam service that are installed on a water-filled loop seal, shall be set-pressure tested with saturated steam. Alternative compressible fluids may be used as the test media if correlation data be1ween the alternative fluid and steam has been established. The requirements of 1-8300 shall apply for testing with alternative test media.
(b) Accumulator Volume. The volume of the accumulator drum and the pressure source flow rate shall be sufficient to determine the valve set-pressure. Valves may have their lifts restricted during set-pressure testing.
(c) Assist Devices. Assist devices may be used for set-pressure testing, provided the accuracy complies with the requirements of 1-1400.
(d) Thermal Equilibrium. Ambient temperature and test media temperature shall be established and valve thermal equilibrium confirmed before starting set-pressure testing. The valve shall be considered at thermal equilibrium only when the valve body temperature has staoilized and does not change more than 10°F (5.5°G) in 30 min as measured directly or determined by correlation from other valve temperature measurements. Valves insulated in service shall be insulated in a like manner during testing. Verification of thermal equilibrium is not required for valves that are tested at ambient temperature using a test medium at ambient temperature.
(e) Ambient Temperature. The ambient temperature of the operating environment shall be simulated during the set-pressure test. If the effect of ambient temperature on set-pressure can be established for a particular valve type, then the valve may be set-pressure tested using an ambient temperature different from the operating ambient temperature. Correlations between the operating and testing ambient temperatures shall comply with the requirements of 1-8320 and 1-8330.
(f) Superimposed Back Pressure (1) Consideration of variable or constant back pressure in set-pressure setting is not required for balanced pressure relief valves, if the back pressure does not exceed 50% of the valve set-pressure. However, the set-pressure shall consider the effects of bonnet pressure when the bonnet vent is piped to a pressure or vacuum discharge other than atmospheric.
8
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(2) Constant superimposed back pressure in setpressure setting shall be considered for non balanced pressure relief valves when the back pressure exceeds 1 % of the set-pressure.
For conventional nonbalanced valves with constant superimposed back pressure, the required set-pressure shall be calculated by subtracting the superimposed back pressure from the stamped setpressure.
(g) Control Rings. Adjustment of control rings to ensure valve action is permitted. For set-pressure acceptance testing, control ring positions shall not be altered between successive openings. Adjusted control rings shall be returned to their proper operating position prior to return to service, as documented by the Owner.
(h) Time Between Valve Openings. A minimum of 5 min shall elapse between successive openings.
(i) Number of Tests. The number of openings at setpressure shall be sufficient to demonstrate satisfactory repeatability with a minimum of two consecutive openings within acceptance criteria. Any subsequent opening at the same set point adjustment shall be within acceptance criteria.
1-8130 Liquid Service (a) Test Media. Valves shall be tested with the normal system operating fluid and temperature for which they are designed. Alternative liquids and different temperatures may be used, provided the requirements of 1-8300 are met.
(b) Accumulator Volume. There is no requirement for minimum accumulator volume; however, the pressure tap for determining set-pressure shall be located at the valve inlet.
(c) Assist Devices. Assist devices to determine set-pressure are not recommended for liquid service pressure relief valves.
(d) Thermal Equilibrium. Ambient temperature and test media temperature shall be established and valve thermal equilibrium confirmed before starting set-pressure testing. The valve shall be considered at thermal equilibrium only when the valve body temperature has stabilized and does not change more than 1 0°F (5.5°C) in 30 min as measured directly or determined by correlation from other valve temperature measurements. Valves insulated in service shall be insulated in a like manner during testing. Verification of thermal equilibrium is not required for valves that are tested at ambient temperature using a test medium at ambient temperature.
(e) Ambient Temperature. The ambient temperature of the operating environment shall be simulated during the set-pressure test. If the effect of ambient temperature on set-pressure can be established for a particular valve type, then the valve may be set-pressure tested using an ambient temperature different from the operating ambient temperature. Correlations between the operating and testing ambient temperatures shall comply with the requirements of 1-8320 and 1-8330.
(f) Superimposed Back Pressure (1) Consideration of variable or constant back pressure in set-pressure setting is not required for balanced pressure relief valves, if the back pressure does not exceed 50% of the valve set-pressure. However, the setpressure shall consider the effects of bonnet pressure when the bonnet vent is piped to a pressure or vacuum discharge other than atmospheric.
(2) Constant superimposed back pressure in setpressure setting shall be considered for non balanced pressure relief valves when the back pressure exceeds 1 % of the set-pressure.
For conventional nonbalanced valves with constant superimposed back pressure, the required set-pressure shall be calculated by subtracting the superimposed back pressure from the stamped setpressure.
(g) Time Between Valve Openings. A minimum of 5 min shall elapse between successive openings.
9
(h) Number of Tests. The number of openings at setpressure shall be sufficient to demonstrate satisfactory repeatability with a minimum of two consecutive openings within acceptance criteria. Unless otherwise stated in the test procedure, valve opening pressure shall be that inlet pressure when a continuous, unbroken stream of liquid is emanating from the valve outlet.
1-8200 Seat Tightness Testing Seat tightness testing shall be performed in accordance with the Owner's valve test procedure.
Consideration shall be given to test media, temperature stability, and ambient temperature, as required in 1-8100. Seat tightness testing shall be performed using the same fluid used for set-pressure testing, except as provided by 1-8300.
1-821 O Inlet Pressure. The inlet pressure for seat leak testing shall be in accordance with one of the following:
(a) maximum system operating pressure
{b) 90% of spring setting or 5 psig {34 kPa) below spring setting for valves having a spring set-pressure less than 50 psig (344 kPa)
(c) pressure established in Owner's valve test procedure 1-8220 Acceptable Seat-Tightness Testing Methods.
Table 1-8220-1 provides acceptable methods. Other methods may be determined by the Owner.
1-8230 Acceptance Criteria for Seat Leakage Testing.
Either the original valve equipment design specification acceptance crlteria or acceptance criteria established by the Owner in the valve test procedure shall be used for valve seat leakage acceptance criteria.
1-9000 PWR RECORDS AND RECORD KEEPING 1-9100 Requirements The Owner shall maintain a record that shall include the following for each valve covered by this Appendix:
(a) the manufacturer and manufacturer's model and serial number, or other identifiers (b) a copy or summary of the manufacturer's acceptance test report, if available (c) preservice test results 1-9200 Record of Tests In addition to the requirements of ISTA-9230, if testing is performed in accordance with 1-8300, a copy of the alternate test media correlation, test procedure, and documentation of results of test performed to verify the adequacy of the alternate test media shall be maintained.
1-9300 Record of Modification and Corrective Ac1ion In addition to the requirements of ISTA-9240, the following requirements shall be met:
(a) The Owner shall document all modifications made to or corrective actions taken that affect the set-pressure of pressure relief devices or valves. The documentation shall also include any recommendations or modifications suggested by the manufacturer. Modification or corrective action, as outlined, shall be recorded and maintained for the period of time as outlined in the Owner's technical specifications.
10
(b) Any device modification or adjustment that affects nameplate data shall be recorded on a data sheet. The modification or adjustment shall be made in accordance with the manufacturer's published information or shall have the concurrence of the manufacturer. An additional nameplate, not bearing a Code symbol stamp, shall be installed to reflect the new data and reference to records maintained by the Owner outlining the modification.
Braidwood Units 1 and 2 Station Third Ten-Year 1ST Interval submitted July 27, 2009, references ASME OM Code 2001 Edition through 2003 Addenda Braidwood 1ST Program specifies:
PORV - fail safe test closed (refueling outage); stroke-time exercise open and closed (refueling outage; and position indication test (2 years).
PORV Block Valve-exercise open and closed {quarterly); and position indication test (2 years).
PSV - Relief Valve Test (5 years); and position indication test (2 years). The 1ST Program references Appendix I to the OM Code for Relief Valve Test.
ASME OM Code 2001 through 2003 Addenda Provisions in ASME OM Code 2001 through 2003 Addenda are essentially the same as the ASME OM Code 2004 through 2006 Addenda with respect to PSVs and POAVs.
11
From:
Sent:
To:
Subject:
- Theresa, Spencer, Michael Tuesday, July 12, 2016 5:12 PM Clark, Theresa RE: Is this really a backfit I went over the original backfit letter again, and I see where you are coming from. However, the staff probably saw its action as requiring a modification of or addition to the facility design, which does fit within the 50.109(a) definition of a backfit. The backfit letter claims that the FSAR discussion is deficient (does not meet 50.34(b)).
and Section 3.4 states, "The NRC staffs current conclusion that Braidwood and Byron's design. b.4ses do not comply with GOCs 15. 21, and 29, and 10 CFR 50.34(b), differs from a previous NRC position on the acceptability of the design bases for these plants as documented in the SE for an increase in reactor power (Reference 1 )." If the design bases are deficient, they must be modified or supplemented to make them sufficient, whic~ is a design change. This is an inference because. as you say, the letter is not clear on the precise actions demanded of the licensee.
Michael
From:
Sent:
To:
Cc:
Subject:
- Les, West, Steven Thursday, July 07, 2016 4:14 PM Cupidon, Les; Hackett, Edwin Difrancesco, Nicholas; Holahan, Gary; Clark, Theresa RE: Some CRGR Follow-up Just to be clear, for RIS 2005-29, the staff requested CRGR review of the RIS and the CRGR decided not to review it? What was documented iin the annual report?
Steve Steven West, Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven.West@nrc.gov From: Cupidon, Les Sent: Thursday, July 07, 201612:10 PM To: Hackett, Edwin <Edwin.Hackett @nrc.gov>
Cc: Difrancesco, Nicholas <Nicholas.Difrancesco@nrc.gov>; Holahan, Gary <Gary.Holahan@nrc.gov>; West, Steven
<Steven.West@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>
Subject:
RE: Some CRGR Follow-up Ed, Below are the search results on the following items:
RIS-2005-29: On September 2, 2005, the CRGR waived RIS 2005-29, "Anticipated Transients That Could Develop Into More Serious Events" (ADAMS Accession No. MLOS1890212). In the past, there were no emailed documentation to t rack t he comments made during the review. Instead we routinely used t he CRGR annual report to document the final decision for reviews of RISS.
NRR Review Standard RS-01 on Extended Power Uprates (2003): I have not found any informat ion in t he CRGR records regarding reviews of this Review Standard. This may be in part to t he fact that per the current CRGR charter, Review Standards are not in the cope of CRGR review.
New Reactor SRP Updates from 2007: I have not found any documented CRGR review of New Reactor SRP updates since 2007 to this date. This is mainly because, according to the current CRGR charter, the staff is not required to have CRGR review any SRPs if it does not contain any new staff positions.
1
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Thanks Les From: Hackett, Edwin Sent: Tuesday, July OS, 2016 9:54 AM To: Cupidon, Les <Les.Cupidon@nrc.gov>
Cc: Difrancesco, Nicholas <Nicholas.DilFrancesco@nrc.gov>; Holahan, Gary <Gary.Holahan@nrc.gov>; West, Steven
<Steven. West@nrc.gov>; Clark, Theresa <The res a. Cla rk@nre.gov>
Subject:
Some CRGR Follow-up Hi Les, Welcome Back!
In coordinating with the Exelon Backfit appeal panel that Gary leads, it would be helpful if you could review the past CRGR record regarding the following:
RIS-2005-29 NRR Review Standard RS-01 on Extended Power Uprates (2003)
New Reactor SRP Updates from 2007 Did the Committee conduct reviews on these and, if so, what were the outcomes?
Gary/Steve - Let us know if there is anything else that comes to mind that would be helpful to the review.
- Thanks, Ed Edwin M. Hackett Deputy Director, Office of Nuclear Regulatory Research USNRC 301-4.25-1904 edwin.hackett@nrc.gov 2
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From:
Spencer, Michael Sent:
Thursday, July 28, 2016 8:45 AM To:
Subject:
West, Steven; Scarbrough, Thomas; Holahan, Gary; Clark, Theresa RE: DRAFT Preliminary Findings July 27 2016 - tvc MAS.docx We did, RIS-99-01, but neither it nor the other pre-2005 documents I could find have the following clear prohibition found in the 2009 and 2015 revisions of MD 8. 18:
RISs may NOT-(c)
- provide guidance for the implementation of rules and regulations, (i)
- provide guidance to NRC staff on regulatory or technical matters, and (ii)
- be used in lieu of other established agency products.
{iii)
The statements in the pre-2005 documents are more ambiguous. For example, the 2004 NRR LIC-503 says:
Regulatory Issue Summary. A regulatory issue summary is an informational document that is used to communicate with the nuclear industry on a broad spectrum of matters having generic applicability. It does not involve a request for action or information unless the request is strictly voluntary. Listed below are examples of way{ lrt'whi¢h:aif~:gliraior{issue ?unim~fy,;;ay be used:
[J Document NRC endorsement of industry-developed resolutions to issues.
D Document NRC endorsement of industry guidance on technical or regulatory matters.
'...I Provide the status of staff interaction with the nuclear industry on a matter.
1 Request the voluntary participation of licensees in staff-sponsored pilot programs.
C Inform licensees of opportunities for regulatory relief.
C Announce' st~fhei:hnical or poUcy positions or, m'atters that h~y~ not be~n broadly communicated to the nucl;ar! i~d~stry lor"ate not "fully Lindersfoo<i.
- : : :: **** i
. * ~:,. '.-::
- 1-.
Provide guid,:rnc'e' to licen,sees on regulatory matters, such as, the.scop~ ahd detail of infqrmation that should b_e provide:d i~. licensirig applicationsto,facilitate st~ff revieW1
[1 Announce the issuance and availability of regulatory documents (topical reports, NU REG-type documents and memoranda documenting the closeout of Generic Safety Issues).
D Request the voluntary submittal of information which will assist the NRC in the administration of the regulatory process.
D Announce changes in regulatory practices that could impact licensees.
Q Announce changes in agency practices that could impact licensees.
The highlighted language might be read broadly without the prohibitions in the current MD. Nonetheless, in this case, perhaps the most powerful statement about the purported limitations of the RIS comes from the RIS itself, which states that no comment was requested on the RIS because it was informational and "does not depart from current regulatory requirements and practice."
Michael From: West, Steven Sent: Wednesday, July 27, 2016 7:10 PM To: Spencer, Michael <Michael.Spencer@nrc.gov>; Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>; Holahan, Gary
<Gary.Holahan@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>
Subject:
RE: DRAFT Preliminary Findings July 27 2016 - tvc MAS.docx 1
Sorry I missed the discussion. I seem to recall that we issued a RIS, or maybe an information notice, to explain the RIS and other changes to our generic communications process after we invented the RIS.
Steve
Original Message -**-----
From: "Spencer, Michael" <Michael.Spencer@nrc.gov>
Date: Wed, July 27, 2016 3:59 PM -0500 To: "Scarbrough, Thomas" <Thomas.Scarbrough@nrc.gov>, "Holahan, Gary" <Gary.Holahan@nrc.gov>, "Clark, Theresa"
<Theresa.Clark@ru:~~gg_y_>, "West, Steven" <Steven.West@nrc.ge:>\\:'.>
Subject:
RE: DRAFT Preliminary Findings July 27 2016 - tvc MAS.docx Finding earlier versions of MD 8.18 and other relevant documents in ADAMS was difficult. Finally having found them and reviewed them. I was not able to do exactly what we discussed in today's meeting because the guidance on RIS scope in 2005 was not as clear as it is now, and one might have interpreted it as allowing a RIS to establish new interpretations. I also looked at NRR LIC-503 from 11/29/2004, and it also did not clearly limit the scope of RISs. However, based on the content of the original RIS, I added the following sentence to the Report: Also, when RIS 2005-29 was originally issued, the staff stated that it did not publish the RIS in the Federal Register for comment because "this RIS is informational and pertains to a NRC staff position that does not depart from current regulatory requirements and practice."
Thus, although one might argue that RISs could have had a broader scope in 2005. the staff explicitly limited the intended scope of RIS-2005-29, possibly so it wouldn't have to publish the document in the Federal Register for comment.
I have updated the 3 PM version that Tom placed in the Report folder. I also updated some of my earlier comments based on discussion at today's meeting. I have closed the document, so it should be open for editing by others.
One more thing, Tom added a sentence stating, "RIS 2005-29 and its draft supplement do not discuss water relief certification requirements in the ASME BPV Code." I just want to point out that I looked at the original RIS again. and there is one place where it seems to be suggesting that safety-related qualification was necessary. This is the following paragraph on page 2: "Since 1993, when this NSAL was issued, most of the affected Westinghouse plants have modified their licensing basis analyses, usuaUy via the Title 10 of the Code of Federal Regulations (10 CFR) Sect.ion.~o:s~ process,,tf Frl~~J.fih~i,M'f r~~r~:n; 9(~ith~~}~~ P~i'R\\%{~r the: p,ress~ri~~r!:safety valves without first tjualifyihg:t~emas ~a{efy~re!~W~ \\fystenis ~ap~ble o'fr~HtMng1:VJatet. The licensing bases of the remaining Westinghouse plants and certain, affected non-Westinghouse PWRs still do not address the nonescalation criterion."
Michael From: Scarbrough, Thomas Sent: Wednesday, July 27, 2016 3:25 PM To: Holahan, Gary <Gary.Holahan@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>; Spencer, Michael
<Michael.Spencer@nrc.gov>; West, Steven <Steven.West@nrc.gov>
Subject:
RE: DRAFT Preliminary Findings July 27 2016 - tvc MAS.docx Based on our discussion today, I have updated the "3 pm version" of the Draft Preliminary Findings and placed it in the S:/Backfit Appeal/Report folder.
Also, I included the Beaver Valley EPU 2006 Letter and SER in the S:Backfit Appeal/References folder. The following is the concurrence chain:
OFFICE LPLl-1/PM LPLl-1/LA AFPB/BC CSGB/BC CPNB/BC EQVA/BC CVIB/BC NAME TColburn Slittle SWeerakody* Llund* TChan* DThatcher* MMitchell*
DATE 7/13/06 7/13/06 06/09/05 09/08/05 08/03/0511/15/0512/28/05 2
OFFICE EEEB/BC AADB/BC IHPB/BC(A) ACVB/BC APLA/BC ACVB/BC SBPB/BC NAME RJenkins* MKotzalas* SKlementowicz* RDennig* MRubin* RDennig* 0Solorio*
DATE 01/05/06 01/13/06 01/18/06 02/01/06 02/28/06 03/01/06 03/09/06 OFFICE EEMB/BC EICB/BC REBB/BC IOLB/BC SPWB/BC SPWB/BC TechEd NAME KManoly* AHowe* RFranovich* NO'Keefe* JNakoski* JNakoski* HChang DATE 03/10/06 03/15/06 03/15/06 03/22/06 04/04/06 04/13/06 06/26/06 OFFICE OGC LPLl-1/BC DORUD NRR/D NAME JMoore Rlaufer CHaney JDyer DATE 07/12/06 07/17/06 07/18/06 7/19/06 Thanks.
Tom From: Holahan, Gary Sent: Wednesday, July 27, 2016 12:55 PM To: Clark, Theresa <Theresa.Clark@nrc.gov>; Spencer, Michael <Michael.Spencer@nrc.gov>; West, Steven
<Steven.West@nrc.gov>; Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>
Subject:
RE: DRAFT Preliminary Findings July 27 2016 - tvc MAS.docx Let's use the 2pm meeting to try to finalize the Preliminary Finding From: Clark, Theresa Sent: Wednesday, July 27, 2016 12:41 PM To: Spencer, Michael <Michael.Spencer@nrc.gov>; Holahan, Gary <Gary.Holahan@nrc.gov>; West, Steven
<Steven.West@nrc.gov>; Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>
Subject:
Re: DRAFT Preliminary Findings July 27 2016 - tvc MAS.docx Something to discuss if we do meet at 2 :)
On: 27 July 2016 12:02, "Spencer, Michael" <Michael.Spencer@nrc.gov> wrote:
Another thought. Should we address this new ASME Code argument that has surfaced in discussions with DE Staff? It seems like we should for completeness, and if we don't, we will probably get that back as a comment.
From: Spencer, Michael Sent: Wednesday, July 27, 201611:11 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>; West, Steven <Steven.West@nrc.gov>; Scarbrough, Thomas
<Thomas.Scarbrough@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>
Subject:
DRAFT Preliminary Findings July 27 2016 - tvc MAS.docx I made comments on top of Theresa's.
3
From:
Sent:
To:
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Mccree, Victor Monday, September 12, 2016 6:22 PM Holahan, Gary; Clark, Theresa
Subject:
FW: Search Results for EDO Overturning the Staff Denial to a licensee's Backfit Appeal See below.
From: Cupidon, Les Sent: Monday, September 12, 2016 4:39 PM To: Hackett, Edwin <Edwin.Hackett@nrc.gov>; Mccree, Victor <Victor.McCree@nrc.gov>; Johnson, Michael
<Michael.Johnson@nrc.gov>
Cc: Weber, Michael <Michael.Weber@nrc.gov>; Tracy, Glenn <Glenn.Tracy@nrc.gov>
Subject:
RE: Search Results for EDO Overturning the Staff Denial to a Licensee's Backfit Appeal
- Vic, After performing an ADAMS search and looking into the ADAMS Backfit Facility-specific folder I have identified various e-mail exchanges that pertain to backfitting. The majority of these e-mails are exchanges between the staff. Few are between the staff and the industry.
With regards to Section I.E.2 in MD 8.4, the rest of the paragraphs states, Except as noted, ADAMS shall be the single repository of all the backfit d¢cisforfrn~Ring, including the outcome of any licensee backfit appeals, as well as cross-references to all the communications issued or received by NRC staff with respect to a facility-specific backfit. All the above-mentioned records shall be managed in accordance with the applicable agency policy and procedures.
It was envision that any documents (including e-mails) that had a bearing on the decisionmaking process regarding backfitting would be considered as input into ADAMS (specifically, the Backfit Facility-specific folder}. This of course did not preclude other document managing requirements that required the staff to place e-mails into ADAMS. Our focus was that for tracking and for historical purposes, future staff would be able to open the Backfit Facility-specific folder and follow the trail from beginning to end (the final disposition regarding a facility-specific backfit).
The statement, "cross-references to all the communications issued or received by NRC staff was referring to communication items (including e-mails) sent (mainly) to and from Industry, or between the staff as it pertained to the trail for the backfitting decision and as is relevant. We were not focusing on e-mail exchanges between the staff that merely discussed the issue, but on those that were directly relate to the backfit decision.
It is recognized that the question regarding what document is related to the decisionmaking process is subject to interpretation. Therefore, the following direction was provided for staff to enter document into ADAMS as prescribed by agency policy.
All the above-mentioned records shall be managed rn accordance with the applicable agency policy and procedures.
Please contact me if you have any further questions (301-613-1971 [WAH P#]).
Thanks Les From: Cupidon, Les Sent: Monday, September 12, 2016 8:43 AM To: Hackett, Edwin <Edwin.Hackett@nrc.gov>; Mccree, Victor <Vktor.McCree@nrc.gov>; Johnson, Michael
<Michael.Johnson@nrc.gov>
Cc: Weber, Michael <Michael.Weber@nrc.gov>; Tracy, Glenn <Glenn.Tracy@nrc.gov>
Subject:
RE: Search Results for EDO Overturning the Staff Denial to a Licensee's Backfit Appeal
- Vic, I am working on this question and will provide an answer to you by COB today.
Thanks Les From: Hackett, Edwin Sent: Friday, September 09, 2016 3:51 PM To: Mccree, Victor <Victor.McCree@nrc.gov>; Cupidon, Les <Les.Cupidon@nrc.gov>; Johnson, Michael
<Michael.Johnson@nrc.gov>
Cc: Weber, Michael <Michael.Weber@nrc.gov>; Tracy, Glenn <Glenn.Tracy@nrc.gov>
Subject:
RE: Search Results for EDO Overturning the Staff Denial to a Licensee's Backfit Appeal Thanks Vic - we will follow-up by Monday.
Ed From: Mccree, Victor Sent: Friday, September 09, 2016 3:42 PM To: Hackett, Edwin <Edwin.Hackett@nrc.gov>; Cupidon, Les <Les.Cupidon@nrc.gov>; Johnson, Michael
<!J1ichael.Johnson@nrc.gov>
Cc: Weber, Michael <Michael.Weber@nrc.gov>; Tracy, Glenn <Glenn.Tracy@nrc.gov>
Subject:
Re: Search Results for EDO Overturning t he Staff Denial to a Licensee's Backfit Appeal Thanks Ed.
I don't want to split hairs or create a new expectation, but while Section I.E. I of DH 8.4 refers to" "Records,"Section I.E.2 refers to "All backfit-related information.... " Perhaps Les can shed light on w hether there was an intent to expand beyond OARs those Backfit appeal documents to be captured in ADAMS.
Vic On: 09 September 2016 15:33, "Hackett, Edwin" <Edwin.Hackett@nrc.gov> wrote:
Hi Vic, Les is out today on CWS. I took a look at the two MD's - 8.4 on Facility Specific Backfitting and 3.53 on Records Management. The portion of MD3.53 that applies (I believe) is 3.53 D2:
Record Status (a) 2
Documentary materials are records when they meet the following two conditions:
They are made or received by an agency of the United States Government under Federal law or in connection with the transaction of agency business. (i)
They are preserved or are appropriate for preservation as evidence of agency organization and activities or because of the value of the information they contain. (ii)
To the extent that the emails meet these tests, they would be considered Federal Records. I am certainly not the expert in this area, but the above is similar to what we have done for record retention in DPO reviews.
Les should have additional insights regarding past practice when he is able to weigh-in.
Hope this helps.
Have a great weekend!
Ed From: Mccree, Victor Sent: Friday, September 09, 2016 8:42 AM To: Cupidon, Les <Les.Cupidon@nrc.gov>; Johnson, Michael <Michael.Johnson@nrc.gov>
Cc: Weber, Michael <Michael.Weber@nrc.gov>; Hackett, Edwin <Edwin.Hackett@nrc.gov>
Subject:
Re: Search Results for EDO Overturning the Staff Denial to a Licensee's Backfit Appeal
- Les, Thanks again for researching this matter. I have another question for you:
Does t he guidance on record keeping in Sect ion I.E.2 of DH 8.4 include internal emails? Specifically, does the requirement to enter "All backfit-related information... " in ADAMS include internal emails exchanged among staff in the course of an appeal review?
Note t hat my intent is to remain consistent with past practice, NOT create a new precedent.
Thanks, in advance, for your help.
Vic On: 30 August 2016 11:52, "Cupidon, l!..es"<Les.Cupidon@nrc.gov> wrote:
- Michael, 3
Per your request to identify instances of the EDO overturning of a staff denial of a plant specific backfit appeal. In my search I have not found any instance of the EDO overturning the office denial of a backfit appeal. However, I am providing you with two office level reversals for consideration. They are concerning the following backfit appeals, (1) Farley: regarding work schedule backfit compliance related to work schedules (attached, "Panel... ") and (2) Oconee, McGuire, and Catawba: regarding containment integrated leakage rate testing {attached, "Oconee... ". With regards to the office director actions, once the staff actions has been determine not to be supported by agency regulatory guidance, the office director informs the licensee regarding the determination with the supporting basis.
Furthermore, it appears in the instance of an office level appeal being overturned a follow up action involved subsequent dissemination of the panel determination to the relevant regions by memorandum (attached "Results... ").
It appears that based on the results of the ADAMS research for precedence of EDO overturning the staff denial of a backfit appeal and the recent Byron/Braidwood backfit appeal panel results, we may be in new territory.
In conclusion, it appears there has been very limited overturns in the office level appeal and none in the EDO level appeal.
I wanted to get this to you soon, although I am still waiting for staff to respond back to me regarding a 2001 Maine Yankee security plan related backfit appeal. The document trail stops abruptly in ADAMS in a January 2002 memo to the utility regarding plans to respond back with the Office Director's determination. I suspect it will not be of interest since the backfit appeal was at the office level. I will close the loop with you soon as I know how this appeal ended.
Please let me know if you need further information.
Thanks Les 4
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Akstulewicz, Frank Thursday, July 21, 2016 9:18 AM Clark, Theresa Holahan, Gary
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RE: REQUEST: meeting with Exelon backfit appeal panel As I understand it, the question here goes back 15 yrs... I need to at least look at the SE to see if I even remember the issue... not even sure what the question of the backfit appeal is.
I could at least propose Tuesday at 2pm...
Does that work??
From: Clark, Theresa Sent: Wednesday, July 20, 2016 4:17 PM To: Akstulewicz, Frank <Frank.Akstulewicz@nrc.gov>
Cc: Holahan, Gary <Gary.Holahan@nrc.gov>
Subject:
REQUEST: meeting with Exelon backfit appeal panel Hi Frank! The EOO appeal panel for the Exelon backfit appeal (Byron/Braidwood PSV/PORV issue) would like to speak with you if possible, since your branch contributed a key input to the 2001 stretch power uprate safety evaluation that is now being considered as part of the backfit. Scheduling time with folks on the panel has been challenging so I'm seeing if there are any spots on your calendar that aren't quite as booked as they appear. In particular I'm looking at 4pm tomorrow (you're shown as booked but 3 of the 4 panel members are available) or 3pm Monday (you have a tentative appointment from 3:15-3:45). 1pm Monday or 2pm Tuesday might also work but I'm selfishly avoiding those because of conflicts I have.
Please let me know if you're willing to take some time with the panel. Thanks so much!
Background
References:
Appeal panel charter: ML16173A311 6/2/16 Exelon backfit appeal to EDO: ML16154A254 5/3/16 NRR backfit appeal decision: ML16095A204 12/8/2015 Exelon backfit appeal to NRR: ML15342A112 10/9/2015 NRC backfit letter: ML1422SA871 8/26/04 pressurizer safety valve setpoint safety evaluation: ML042250531 5/4/01 stretch power uprate safety evaluation: ML033040016 3/15/01 SRXB input to stretch power uprate safety evaluation: ML010740316 Theresa Valentine Clark Executive Technical Assistant (Reactors)
U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0-16E22 1
All documents are publicly available in ADAMS.
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- Carolyn, Holahan, Gary Wednesday, August 17, 2016 5:40 PM Wolf, Carolyn Dean, Bill; Wertz, Trent RE: Potential due outs from yesterday's briefing with Andy Zach (Aug 9, 2016)
I'm not aware of any "1977 policy statement on EPRI backfit." Im fact I'm quite sure there is no such thing. ERPI never was a licensee, so there couldn't be an ERPI backfit.
I'm working on the appeal of an Exelon compliance backfit (2015) for the EDO, and we tiave referenced a 1977 SECY paper (SECY-77-439). It's not a policy statement and it doesn't mention EPRI. So it hard to see how it fits the request.
The SECY paper is available in ADAMS, ML060260236, but I have no idea if it fits the request, since I have no background or context.
SECY-77-8439 is publicly available in ADAMS as ML060260236.
I would like to be more helpful, but that's all 1 can offer unless you can get me more information, Gary From: Wolf, Carolyn Sent: Wednesday, August 17, 2016 4:39 PM To: Holahan, Gary <Gary.Holahan@nrc.gov>
Subject:
RE: Potential due outs from yesterday's briefing with Andy Zach (Aug 9, 2016)
- Gary, Are you familiar with the document that Bill Dean is referring to in the email below? We committed to sending it to a congressional staffer, but I am unsure of what document we are to send. Thanks for the help.
Carolyn K. Wolf (formerly Carolyn Kahler)
Congressional Affairs Officer U.S. Nuclear Regulatory Commission Location: 0 \\VFN-3E9 Phone: 301-415-8492 Cell: l(b)(6)
I Emiul:
rol;n.wolf@orc.go\\*
From: Wertz, Trent Sent: Wednesday, August 17, 2016 10:11 AM To: Wolf, Carolyn <Carolyn.Wolf@nrc.gov>
Subject:
FW: Potential due outs from yesterday's briefing with Andy Zach (Aug 9, 2016)
- Carolyn,
See below. You should check with Gary to see if he can point you to the document.
Trent From: Dean, Bill Sent: Tuesday, August 16, 2016 5:34 PM To: Wertz, Trent <Trent. Wertz@nrc.gov>
Subject:
Re: Potential due outs from yesterday's briefing with Andy Zach (Aug 9, 2016)
It is a document that Gary holahan is referring to as part of the backfit appeal and that we address in our response.
On: 16 August 2016 15:12, Wertz, Trent" <Trent.Wertzl@nrc.g9y> wrote:
- Bill, See below. I spoke to Carolyn about this. There is no 1977 policy statement on an EPRI Backfit (at least not in the Commission documents on the website). Did she misinterpret the conversation or misunderstand what was being discussed? Any light you can shed on this would be helpful.
Hope you're enjoying the conference.
Trent From: Wolf, Carolyn Sent: Monday, August 15, 2016 11:48 AM To: Wertz, Trent <Trent.Wertz@nrc.gov>
Subjed: Re: Potential due outs from yesterday's briefing with Andy Zach (Aug 9, 2016)
Do you know anyone in the office who might know the ML number? Or have a hard copy of it? I'm not sure what the policy statement actually is. Thanks for some direction!
On: 15 August 2016 10:52, 11Wertz, Trent" <Trent. Wertz(a)nrc.gov> wrote:
I do not. I did a couple of searches in ADAMS for it and did not have any luck.
From: Wolf, Carolyn Sent: Friday, August 12, 2016 3:18 PM To: Wertz, Trent <Trent.Wertz@nrc.gov>
Cc: Mahoney, Michael <Michael.Mahoney@nrc.gov>
Subject:
RE: Potential due outs from yesterday's briefing with Andy Zach (Aug 9, 2016)
- Trent, Do you happen to have the ML number for the 1977 policy statement on EPRI backfit? I'm not finding it on the NRC website.
Carolyn K. Wolf (formerly Carol)"n Kahler)
Congressional Affairs Officer U.S. :t\\uclcar Regulatory Commission Location: O\\VFN-3E9 2
From: Dean, Bill Sent: Wednesday, August 10, 2016 10:15 PM To: Wolf, Carolyn <Carolyn.Wolf@nrc.gov>
Cc: Colgary, James <James.Colgary@nrc.gov>; Dacus, Eugene <Eugene.Dacus@nrc.gov>; Hackett, Edwin
<Edwin.Hackett@nrc.gov>
Subject:
Re: Potent ial due outs from yesterday's briefing with Andy Zach (Aug 9, 2016)
Looks fine. Ed Hackett of RES can help on the meeting.
On: 10 August 201618:12, "Wolf, Carolyn" <Carolyn.Wolf@nrc.gov> wrote:
- Bill, Thank you so much for meeting with Andy Zach yesterday. Great briefing. I've created a small list of potential due outs that I captured. Let me know if you think that there are any items that do not belong on the list or if there is anything I should add. Thanks!
NRR Provide the 1977 policy statement on EPRI backfit Send information on the September 13 (?) CRGR meeting Carolyn K. Wolf (formerly Carolyn Kahler)
Congressional Affairs Officer U.S. Nuclear Regulatory Commission Location: OWFN-3£9 Phone: 301-415-8492 Cell: (b )(6l 3