ML19304A132

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NRC-2017-000292 (Formerly FOIA/PA-2017-0292) - Resp 3 - Interim. Agency Records Subject to the Request Are Enclosed (NRR)
ML19304A132
Person / Time
Issue date: 10/11/2019
From:
NRC/OCIO
To:
References
FOIA, FOIA/PA-2017-0292, NRC-2017-000292
Download: ML19304A132 (23)
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Text

Unless otherwise noted, a ll documents are publidy available in ADAMS under th e specified a ccession number.

From : Whitman. 1ennjfer To: Taylor Robert Cc: McGjnty Tim; Benner Erjc; Stychel/. Sheldon; Billerbeck I ohn; Lubinski lohn; Orf. Tracy; Lund Loyjse* Alley.

QfildQ; Garmoe. Alex Subject : Backfit References Date: Thursday, August 04, 2016 11:31:56 AM This EPRI repo rt is publicly available at Atta chments: NP-2770-LDY] pdf https ://www. epri.com/#/pages/product/N P-2770- LDVl/

Below are links t o many of the references (some are on ly microfiche add resses)

1. Memorandum from Edson G. Case, NRC, to the Comm issioners, SECY-77-439, "Single Failure Criterion," dated August 17, 1977. ADAMS Accession No. ML060260236.
2. NP-2770-LDV1 -EPRI/C-E PWR Safety Valve Test Report , dated January 1983. [Not in ADAMS - attached to this e-mail] This r eport ma y be found at https ://www.epri. com/ #/pages/pro duct/NP-2770-LDVl/.
3. R.J. Dickinson and J.G. Bass, Westinghouse Electric Corporation, "Pressurizer Safety Relief Valve Operation for Water Discharge during a Feedwater Line Break," WCAP-11677, dated January 1988. [not in ADAMS - microfiche 49755:336-49756:0171 The document Is included in ML16342D412 [page 37 of PDF file]
4. Letter from L. Olshan, U.S. NRC, to Henry E. Bliss, Commonwealth Edison Company, "NUREG-0737, Item 11.D.1 , Performance Testing on Relief and Safety Valves for Byron Station, Units 1 and 2," dated August 18, 1988. ADAMS Accession No. ML003772409

[pages 161 -188 of PDF file].

5. Letter from S. Sands, U.S. NRC, to Thomas J. Kovach, Commonwealth Edison Company, "NUREG-0737, Item 11.D.1, "Performance Testing on Relief and Safety Valves for Braidwood Station, Units 1 and 2," dated May 21, 1990. ADAMS Accession No. ML003772409 [pages 189-217 of PDF file].
6. Letter from Anthony H. Hsia, U.S. NRC, to Thomas J. Kovach, Commonwealth Edison Company, "Issuance of Amendments (TAC Nos. M77332, M77333, M77334, M77335, M77402, M77403, M77404, and M77405)," dated November 18 1991. [not in ADAMS

- microfiche 55918*317-344) This document is publicly avail able in ADAMS as

. ML020860105

7. Letter from K.L. Grasser, Commonwealth Edison Company, to U.S. NRC, "Change to Credit Automatic PORV Operation for Mitigation of Inadvertent Safety Injection at Power Accident," dated May 29, 1998. [not in ADAMS - microfiche A3765:275-301]

Thi s document is publicly available In ADAMS as ML19204A039

8. Letter from R.M. Krich , Commonwealth Edison Company, to U.S. NRG, "Response to Request for Additional Information Regarding License Amendment Request to Credit Automatic Power-Operated Relief Valve (PORV) Operation for Mitigation of Inadvertent

Safety Injection at Power Accident and Withdrawal of License Amendment Request,"

~----,--~-.....,....,..--,---.,....,....,.----,

dated July 16, 1999. [not in ADAMS - microfiche A8671 :349-354] This document is publicly available in ADAMS as ML19204A038

9. Letter from R.M. Krich, Commonwealth Edison Company, to U.S. NRC, "Response to Request for Additional Information Regarding the License Amendment Request to Permit Uprated Power Operations at Byron and Braidwood Stations," dated November 27, 2000. ADAMS Accession No. ML003772461.
10. Letter from George F. Dick, Jr., U.S. NRC, to Oliver D. Kingsley, Exelon Generation Company, LLC, "Issuance of Amendments; Increase in Reactor Power, Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 (TAC Nos. MA9428, MA9429, MA9426, and MA9427)," dated May 4, 2001. ADAMS Accession No. ML033040016.
11. Letter from George F. Dick, Jr., U.S. NRC, to Christopher M. Crane, Exelon Generation Company, LLC, "Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 -

Issuance of Amendments, Re: Pressurizer Safety Valve Setpoints, (TAC Nos. MB9762, MB9763, MB9760, and MB9761 )," dated August 26, 2004. ADAMS Accession No. ML042250531 .

12. NUREG/CR-7037, "Industry Performance of Relief Valves at U.S. Commercial Nuclear Power Plants through 2007," dated March 2011. ADAMS Accession No. ML110980205.
13. Letter from Joel S. Wiebe, U.S. NRC, to Michael J. Pacilio, Exelon Generation Company, LLC, "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2

- Issuance of Amendments Regarding Measurement Uncertainty Recapture Power Uprate (TAC Nos. MF2418, MF2419, MF2420, and MF2421)," dated February 7, 2014.

ADAMS Accession No. ML13281 AOOO.

14. Memorandum from Samuel Miranda, U.S. NRC, to Christopher P. Jackson, U.S. NRC, "Making Non-Concurrence NCP-2013-04 Public," dated February 28, 2014. ADAMS Accession No. ML14063A174.
15. "Byron/Braidwood Nuclear Stations Updated Final Safety Analysis Report (UFSAR)

Revision 15," dated December 2014. ADAMS Accession No. ML14363A398.

16. Letter from Anne T. Boland, U.S. NRC, to Bryan Hanson, Exelon Generation Company, LLC, "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 - Backfit Imposition Regarding Compliance with 10 CFR § 50.34(b), GDC 15, GOC 21, GDC 29,

and Licensing Basis (TAC Nos. MF3206, MF3207, MF3208, and MF3209)," dated October 9, 2015. ADAMS Accession No. ML14225A871 .

17. Letter from J. Bradley Fewell, Exelon Generation Company, LLC, to William M. Dean, U.S. NRG, "Appeal of Imposition of Backfit Regarding Compliance with Title 1O of the Code of Federal Regulations (10 CFR) Section 50.34(b), General Design Criteria (GDC) 15, GDC 21, GDC 29, and Licensing Basis," dated December 8, 2015. ADAMS Accession No. ML15342A112.
18. Memorandum from Anthony T. Gody, Jr., U.S. NRG, to Marissa G. Bailey, U.S. NRG, "Input for Exelon Backfit Review Panel," dated March 21, 2016. ADAMS Accession No. ML16081A405 [non-public].
19. Letter from William M. Dean, U.S. NRG, to J. Bradley Fewell, Exelon Generation Company, LLC, "U.S. Nuclear Regulatory Commission Response to Backfit Appeal -

Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2," dated May 3, 2016. ADAMS Accession No. ML16095A204.

20. Letter from J. Bradley Fewell, Exelon Generation Company, LLC, to Victor M. McCrea, U.S. NRC, "Appeal of Imposition of Backfit Regarding Compliance with 10 CFR § 50.34(b), General Design Criteria (GDC) 15, GDC 21, GDC 29, and Licensing Basis,"

dated June 2, 2016. ADAMS Accession No. ML16154A254.

21. Letter from Anthony R. Pietrangelo, NEI, to Victor M. Mccree, U.S. NRG, "Nuclear Energy Institute Comments in Support of Exelon Generation Company Second-Level Backfit Appeal," dated June 16, 2016. ADAMS Accession No. ML16208A008 [not yet public].
22. Memorandum from Victor M. McCrea, U.S. NRG, to Gary M. Holahan, K. Steven West, Thomas G. Scarbrough, and Michael A. Spencer, U.S. NRG, "Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(b),

GDC 15, GDC 21 , GDC 29, and the Licensing Basis," dated June 22, 2016. ADAMS Accession No. ML16173A311 [non-public].

p~e11,1(/~

Acting Technical Assistant NRR/ DSS Office: 01 O- H22 Phone: (301) 415-3253

A.3 Compliance Backfits

Background:

  • In 1973, ANS 18.2-1973 was issued and licensees incorporated it into their FSARs. This standard classifies transients and accidents according to frequency of occurrence and preserves this classification by requiring non-escalation.

Inadvertent safety injection (anticipated operational occurrence (AOO), Condition II) fills the pressurizer and causes water relief through power operated relief valves (PORVs).

Unqualified PORVs stick open resulting in a small break loss of coolant accident (SBLOCA, Condition Ill) with the frequency of an AOO (Condition II), which violates the design requirements for AOOs.

If, inadvertent safety injection is shown to not fill the pressurizer and PORVs relieve only steam, then the AOO (Condition II) design requirements are met.

  • Between 2005 and now several licensees have made improvements to analyses and/or the plant to address this issue.

Recent Actions:

The NRC staff issued a compliance backfit to the Braidwood and Byron stations on October 9, 2015 (ADAMS Accession No. ML14225A871 ). On December 9, 2015, Exelon informed the staff that it was submitting a letter to the NRR Office Director to appeal the backfit. NRC Management Directive 8.4, "Management of Facility-Specific Backfitting and Information Collections," describes the NRC backfit process including the backfit appeal process.

The compliance backfit was issued for the following reasons:

  • UFSAR Chapter 15 - three events fail to demonstrate compliance with the non -

escalation requirement:

  • Inadvertent Operation of the Emergency Core Cooling System; Chemical and Volume Control System Malfunction that Increases RCS Inventory; and Inadvertent Operation of a power-operated relief valve (PORV).
  • Other issues identified in the same Chapter 15 events including:

o Non-conservative assumption that PORVs and pressurizer spay are inoperable o Prolonged water relief through pressurizer safety valves (PSVs)

  • PSVs are not water-qualified per the American Society of Mechanical Engineers

o Incorrect statements in Updated Final Safety Analysis Report From: Garmoe, Alex Sent: Thursday, September 15, 2016 8:31 AM To: Gody, Tony

Subject:

RE: Exelon Backfit Appeal Panel Report Attachments:

! Non-Responsive Record I did as well - love the warm muggy weather (not enough of it in Region Ill, where I came from!) and was able to do a bit of traveling.

On a separate topici Non-Responsive Record On the topic of backfitting. I just got word minutes ago from Theresa Clark in the EDO's office that issuance of Vic's decision 1s **imminent.'*

Alex From: Gody, Tony Sent: Thursday, September 15, 2016 7:34 AM To: Garmoe, Alex

Subject:

RE: Exelon Backfit Appeal Panel Report We did, thanks. Appreciate the info. You?

From: Garmoe, Alex Sent: Th ursday, September 15, 2016 7:26 AM To: Gody, Tony <Tony.Gody@nrc.gov>; Bailey, Marissa <Marissa.Bailey@nrc.gov>; Gendelman, Adam

<Adam.Gendelman@nrc.gov>

Subject:

RE: Exelon Backfit Appeal Pane l Report I am only hearing rumors but I believe Vic plans to issue his decision pretty soon. I heard there were some last ditch efforts among senior management to discuss the issue wrth Vic. I was also just recently (yesterday) asked to provide a list of names of people involved in the backfit and appeal so they could be made personally aware of the appeal being granted before issuance of the dec1s1on. I don't have anything more concrete than that at the moment - if I hear further updates I'll keep you informed.

I hope you all llad a warm relaxing summer!

From: Gody, Tony Sent: Wednesday, September 14, 2016 4:35 PM To: Bailey, Marissa <Manssa.Bailey@nrc.gov>; Gendelman, Adam <Adarn.Gendelman@nrc.gov>; Garmoe, Alex

<Alex.Garmoe@nrc.gov>

Subject:

RE: Exelon Backfit Appeal Panel Report Any status?

From: Bai ley, M arissa Sent: Wednesday, August 24, 2016 12:56 PM To: Gody, Tony <Tony.Gody@nrc.gov>; Gendelman, Adam <Adam.Gendelman@n rc.gov>; Garmoe, Alex

<Alex.Garmoe@nrc.gov>

Subject:

FW: Exelon Backfit Appeal Panel Report FYI From: Dean, Bill Sent: Wednesday, August 24, 2016 12:50 PM To: Hol ahan, Gary <Gary.Holahan@nrc.gov>; McDermott, Brian <Brian.McDermott@nrc.gov>; Evans, Michele

<Michele Evans@nrc.gov>; McGinty, Tim <Tim McGinty@nrc.gov>; Luibinski, John <John.Lubinski@nrc.gov>

Cc: McCree, Victor <V1ctor.McCree@nrc.gov>; Johnson, Michael <Michael.Johnson@nrc.gov>; West, Steven

<Steve111.West@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>; Scarbrough, Thomas

<Thomas.Scarbrough@nrc.gov>; Spencer, Michael <Michae l.Spencer@nrc.gov>; Uhle, Jennifer

<Jennifer. Uhle@nrc.gov>; Bailey, Marissa <Marissa.Bailey@nrc.gov>

Subject:

Re: Exelon Backfit Appea l Panel Report Ok. Thanks for Lhe due diligence and the efforts of your team. Guess this exemplifies that how the agency implements the backfit rule is an area that warrants the CRGR effort to make the backfiring landscape clearer as similarly intelligent and experienced staff and managers would disagree with this outcome.

On: 24 August 20 16 12:31 , "Holahan, Gary" <(iar\.Holah.in<£t*nrc.~o, > wrote:

NRA, The Exelon backfit appeal panel delivered its report to the EDO and DEDO this morning (ML16236A202 and ML 16236A20). The panel reviewed the NRA response to the panel's preliminary findings, but could not agree with the NRA positions. The report therefore recommends to the EDO that he support the Exelon appeal. The report will be distributed today at the EDO's request.

The EDO will make his final decision after studying the report and considering any feedback from NRR and other stakeholders.

The panel is available to discuss the report with you and respond to your questions, Gary 2

From: Garmoe, Alex Sent: Friday, September 30, 2016 9:15 AM To: Keene, Todd Cc: Stuchell, Sheldon; Mahoney, M ichael

Subject:

FW: 4Q Accomplishments and Chal lenges Attachme nts: Q4 2016 Accomplishments and Challenges - Backfit Info.docx Importance: High Todd, Could you take a look at what I added 1n red and expand/correct as necessary based on what you've heard?

Once you and I align we can send it down to DE for a quick review This is a hot request trom Mike so if we can get it to DE for review later today that wou ld be great.

Thanks.

Alex From: Mahoney, Michael Sent: Fr iday, September 30, 2016 8:30 AM To: Stuchell, Sheldon; Garmoe, Alex Subje ct: FW: 4Q Accompl ishments and Challenges Importance: High

Guys, We need to develop a challenge for and mit1gat1on strategy for backfit for the 40 NRR Accomplishments and Challenges. Due Monday by 3pm. Please work with DE and others as necessary.

Thanks Mike From: Wertz, Trent Sent: Friday, September 30, 2016 8:06 AM To: Anderson, Shaun <Shaun.Anderson@nrc..gov>; Chaze ll, Russe ll <Russell.Chazell@nrc.gov>; Davidson, Evan

<Evan .Davidson@nrc.gov>; Mahoney, Michael <M1chael.Mahoney@nrc.gov>; Orf, Tracy <Tracy.Orf@nrc.gov>; Proffitt, Andrew <Andrew Proffitt@nrc.gov>; Schmitt, Ronald <Ronald.Schm1tt@nrc.gov>; Dickson, El ijah

<Elijah.D1ckson(cvnrc.gov>; Moulton, Charles <Charles.Mou lton@nrc.gov>

Subject:

4Q Accomplishments and Challenges Importa nce: High

All, Attached is the list of 40 accomplishments along with the challenges that were submitted for 03. As you can see, there are no accomplishments listed (I searched the Daily Notes and Weekly Highlights and found nothing). If you have any accomplishments that your division thinks should be included please send them to me. Also, for any challenges that you are responsible for, please review the write ups for the challenge and the mitigation and update as necessary.

For DPR and DE, we were instructed to add a challenge for backfit. Not sure who has the lead for it but will need what the challenge is and what the mitigation strategy is.

Due to me by 3 pm Monday, 10/3. We'll go over at the meeting on Monday.

Let me know if you have any questions.

Trent L. Wertz Technical Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent. wertz@nre.gov 2

Q3 2016 Accomplishments Challenges Non-Responsive Record Non-Responsive Record Non-Responsive Record

Non-Responsive Record Non-Responsive Record Backfit - The EDO reversed a decision by NRR staff and an NRA-sponsored independent appeal panel to issue a compliance backfit to the Braidwood and Byron facilities. Specifically, the EDO determined that there was not a known and established standard where NRA staff believed there was.

Mitigation - <<NRR specific short term action?>> In addition, from an Agency-wide perspective, the CRGR has been tasked by the EDO with reviewing the Agency's backfit guidance and implementation to determine areas for improvement. NRA staff will take any necessary actions in response to the CRGR's findings once the CRGR review is complete, which is expected in early CY2017.

From: Garmoe, Alex Sent: Friday, September 30, 2016 9:40 AM To: Keene, Todd Cc: Stuchell, Sheldon; Mahoney, Michael

Subject:

RE: 4Q Accomplishments and Chal lenges Attachments: Q4 2016 Accomplishments and Challenges - Backfit Info jtk and adg.docx Todd.

I incorporated what you added into the first sentence of tl1e reply. Does it look good to you? If so. I'll pass it to DE for a check.

Alex From: Keene, Todd Sent: Friday, September 30, 2016 9:29 AM To: Garmoe, Alex Cc: Stuchell, Sheldon; Mahoney, Michael

Subject:

RE: 4Q Accomplishments and Chal lenges I made an addition to the attached document.

I left it vague since the direction in the EDO's letter to Bil l did not direct us to issue another generic commun1cat1on.

The EDO's response and direction from the letter 1s included below.

Response: I agree. The report reveals the need to assess the treatment of the underlying technical issue described in the 1993 Westinghouse Nuclear Safety Advisory Letter (NSAL-93-013) on PSV performance after water discharge at pressurized-water reactors. In addition, given the decision communicated herein, the positions included in Regulatory Issue Summary 2005-29, as well as its proposed Revision 1, should be (re)assessed through the appropriate generic process to ensure they receive appropriate backlit consideration. The Director of NRR should inform me within 120 days of the plan to respond to these issues.

I wtll be meeting with DE next week to try and get a timeline, but this is going to be a combined DSS and DE effort to review the technical considerations.

Todd From: Garmoe, Alex Sent: Friday, September 30, 2016 9:15 AM To: Keene, Todd <Todd.Keene@nrc.gov>

Cc: Stuchell, Sheldon <Sheldon.Stuchell@nrc.gov>; Mahoney, Michael <M1chael.Mahoney@nrc.gov>

Subject:

FW: 4QAccomplishments and Challenges Importance: High

Todd,

Could you take a look at what I added in red and expand/correct as necessary based on what you've heard?

Once you and I align we can send it down to DE for a quick review. This is a hot request from Mike so if we can get it to DE for review later today that would be great.

Thanks, Alex From: Mahoney, Michael Sent: Friday, September 30, 2016 8:30 AM To: Stuchell, Sheldon <Sheldon.Stuchel1 l@nrc.gov>; Garmoe, Alex <Alex.Garmoe@nrc.gov>

Subject:

FW: 4Q Accomplishments and Challenges Importance: High Guys.

We need to develop a challenge for and mit1gat1on strategy for backfit for the 40 NRA Accomplishments and Challenges. Due Monday by 3pm. Please work with DE and others, as necessary.

Thanks Mike From: Wertz, Trent Sent: Friday, September 30, 2016 8:06 AM To: Anderson, Shaun <Shaun.Anderson@nrc.gov>; Chazell, Russell <Russell.Chaze ll@nrc.gov>; Davidson, Evan

<Evan.Oavidson@nrc.gov>; Mahoney, Michael <M1chael.Mahoney@nrc.gov>; Orf, Tracy <Tracy.Orf@nrc.gov>; Proffitt, Andrew <Andrew.Proffitt@nrc.gov>; Schmitt, Ronald <Ronald.Schmitt@nrc.gov>; Dickson, Elijah

<Eli jah.Dickson@nrc.gov>; Moulton, Charles <Charles.Moulton@nrc.gov>

Subject:

4Q Accomplishments and Cha l lenges Importance: High All ,

Attached is the list of 40 accomplishments along with the challenges that were submitted for 03. As you can see, there are no accomplishments listed (I searched the Daily Notes and Weekly Highlight s and found nothing). If you have any accomplishments that your division thinks should be included please send them to me. Also, for any challenges that you are responsible for, please review the write ups for the challenge and the mitigation and update as necessary.

For DPR and DE, we were instructed to add a challenge for backfit. Not sure who has the lead for it but will need what the challenge is and what the mitigation strategy is.

Due to me by 3 pm Monday, 10/3. We'll go over at the meeting on Monday.

Let me know if you have any questions.

Trent L. Wertz Technical Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent.wertz@nrc.gov 2

Q3 2016 Accomplishments Challenges Non-Responsive Record Non-Responsive Record Non-Responsive Record

Non-Responsive Record Non-Responsive Record Backfit - The EDO reversed a decision by NRA staff and an NRA-sponsored independent appeal panel to issue a compliance backfit to the Braidwood and Byron facilities. Specifically, the EDO determined that there was not a known and established standard where NRR staff believed there was.

Mitigation - The EDO in a letter to Bill Dean requested that NRR develop a plan within 120 days to assess through a generic process the technical issues discussed in RIS 2005-29 and the proposed Revision 1 to that RIS to ensure appropriate backfit consideration is given. In addition, from an Agency-wide perspective, the CRGR has been tasked by the EDO with reviewing the Agency's backfit guidance and implementation to determine areas for improvement. NRR staff will take any necessary actions in response to the CRGR's findings once the CRGR review is complete, which is expected in early CY2017. /\dditionallv, NRR staff will assess the tEJchnical issue thatpreciPitated the NRR s_laff's initial decision wi_th currQnt rOfil.Jlatory issue summaries through a generic process to ensure that thev receive appropriate b~ckfit consideration.

From: Garmoe, Alex Sent: Friday, September 30, 2016 9:51 AM To: Whit man, Jennifer; Oesterle, Eric Cc: Stuchel l, Sheldon

Subject:

ACTION: FW: 4Q Accomplishments and Challenges Attachments: Q4 2016 Accomplishments and Challenges - Backfit Info jtk and adg.docx Importance: High Eric and Jen.

We (DPR) were asked to add info about the 8/B backfit to the attached accomplishments/challenges list. It's a short turnaround request from our TA (Mike Mahoney). Could you please review the info Todd Keene and I added to the attached file and provide comments or edits 1f you have any? A response by COB today would be awesome if possible Thanks.

Alex From: Mahoney, Michael Sent: Friday, September 30, 2016 8:30 AM To: Stuchel l, Sheldon; Garmoe, Alex

Subject:

FW: 4QAccomplishments and Cha llenges Importance: High Guys.

We need to develop a challenge tor and mitigation strategy for backfit for the 40 NRR Accomplishments and Challenges. Due Monday by 3pm. Please work with DE and others, as necessary.

Thanks Mike From: Wertz, Trent Sent: Friday, September 30, 2016 8:06 AM To: Anderson, Shaun <Shaun.Anderson@nrc.gov>; Chazell, Russell <R!,!ss~II.Chazell@nrc.gov>; Davidson, Evan

<Evan.Davidson@nrc.gov>; Mahoney, Michael <Michael.Mahoney@nrc.gov>; Orf, Tracy <Tracy.Orf@nrc.gov>; Proffitt, Andrew <Andrew.Proffitt@nrc.gov>; Schmitt, Ronald <Ronald.Schm1tt@nrc.gov>; Dickson, Elijah

<Elijah Dickson@nrc.gov>; Mou lton, Charles <Charles.Moulton@nrc.gov>

Subject:

4Q Accomplishments and Challenges Importance: High

All, Attached is the list of 40 accomplishments along with the challenges that were submitted for 03. As you can see, there are no accomplishments listed (I searched the Daily Notes and Weekly Highlights and found nothing). If you have any accomplishments that your division thinks should be included please send them to

me. Also, for any challenges that yoiu are responsible for, please review the write ups for the challenge and the mitigati1on and update as necessary.

For DPR and DE, we were instructed to add a challenge for backfit. Not sure who has the lead for it but will need what the challenge is and what the mitigation strategy is.

Due to me by 3 pm Monday, 10/3. We'll go over at the meeting on Monday.

Let me know if you have any questions.

Trent L. Wertz Technical Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent. wertz@nrc.gov 2

03 2016 Accomplishments Challenges Non-Responsive Record Non-Responsive Record Non-Responsive Record

Non-Responsive Record Non-Responsive Record Backfit - The EDO reversed a decision by NRA staff and an NRA-sponsored independent appeal panel to issue a compliance backfit to the Braidwood and Byron facilities. Specifically, the EDO determined that there was not a known and established standard where NRR staff believed there was.

Mitigation - The EDO in a letter to Bill Dean requested that NRR develop a plan within 120 days to assess through a generic process the technical issues discussed in RIS 2005-29 and the proposed Revision 1 to that RIS to ensure appropriate backfit consideration is given. In addition, from an Agency-wide perspective, the CRGA has been tasked by the EDO with reviewing the Agency's backfit guidance and implementation to determine areas for improvement. NRA staff will take any necessary actions in response to the CRGR's findings once the CRGR review is complete, which 1s expected in early CY2017. Additionalh'.I: NRR staff 1Nill assess the technical issue that_precipitated 1b_Q f!>JF3.8..§!aff's initial decision with current regulatory issue summaries through a_generic procesg to ensure that they receive appl..QQ:fiQ.!Q backfit consideration.

From: Garmoe, Alex Sent: Friday, September 30, 2016 10:47 AM To: Mahoney, Michael Cc: Stuchell, Sheldon; Oesterle, Eric

Subject:

RE: 4Q Accomplishments and Challenges Attachments: Q4 2016 Accomplishments and Challenges w Backfit Info.docx

Mike, Attached is an updated Accomplishments and Challenges file with the requested backfit information. which was coordinated between DSS (techn ical lead for the B/B backfit issue) and DPR. Let me know if you have any questions.
Thanks, Alex From: Mahoney, Michael Sent: Friday, September 30, 2016 8:30 AM To: Stuchel l, Sheldon; Garmoe, Alex

Subject:

FW: 4Q Accomplishments and Challenges Importance: High

Guys, We need to develop a challenge for and mitigation strategy for backfit for the 40 NRR Accomplishments and Challenges Due Monday by 3pm. Please work with DE and others. as necessary.

Thanks Mike From: Wertz, Trent Sent: Fr iday, September 30, 2016 8:06 AM To: Anderson, Shaun <Shaun.Anderson@nrr.gov>; Chazell, Russe ll <Ru~sell.Chazell@nrc.gov>; Davidson, Evan

<Evan.Dav1dson@nrc.gov>; Mahoney, Michael <Michael.Mahoney@nrc.gov>; Orf, Tracy <Tracy.Orf@nrc.gov>; Proffitt, Andrew <Andrew.Proffitt@nrc.gov>; Schmitt, Ronald <Ronald.Schmrtt@nrc.gov>; Dickson, Elijah

<Eliiah.Dickson@nrc.gov>; Moulton, Charles <Charles.Mou lton@nrc.gov>

Subject:

4Q Accomplishments and Challenges Importance: High All ,

Attached is the list of 40 accomplishments along with the challenges that were submitted for 03. As you can see, there are no accomplishments listed (I searched the Daily Notes and Weekly Highlights and found nothing). If you have any accomplishments that your division thinks should be included please send them to me. Also, for any challenges that you are responsible tor, please review the write ups for the challenge and the mitigation and update as necessary.

For DPR and DE, we were instructed to add a challenge for backfit. Not sure who has the lead for it but will need what the challenge is and what the mitigation strategy is.

Due to me by 3 pm Monday, 10/3. We'll go over at the meeting on Monday.

Let me know if you have any questions.

Trent L. Wertz Technical Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent. wertz@nrc..gov 2

Q3 2016 Accomplishments Challenges Non-Responsive Record Non-Responsive Record Non-Responsive Record

!Non-Responsive Record Non-Responsive Record Non-Responsive Record Backfit - The EDO reversed a decision by NRR staff and an NRA-sponsored independent appeal panel to issue a compliance backfit to the Braidwood and Byron facilities. Specifically, the EDO determined that the compliance backfit threshold was not met based on ambiguity surrounding the known and established standard demonstrated by NRR staff.

Mitigation - The EDO in a letter to Bill Dean requested that NRR develop a plan within 120 days to assess, through a generic process, the technical issues regarding pressurizer safety valve performance after water discharge and associated discussions in RIS 2005-29 and the proposed Revision 1 to that RIS to ensure appropriate backfit consideration is given. In addition, from an Agency-wide perspective, the CRGR has been tasked by the EDO with reviewing the Agency's backfit guidance and implementation to determine areas for improvement. NRA staff will take any necessary actions in response to the CRGR's findings once the CRGR review is complete, which is expected in early CY2017.

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