Text

NRC-2019-000253 - Resp 5 - Interim. Agency Records Subject to the Request Enclosed. Part 3 of 4
	ML20197A084
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Issue date:	06/26/2020
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ML20197A080	List: ML20197A081; ML20197A082; ML20197A083; ML20197A084; ML20197A085;
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From: Biemer Kenneth To: ALL.Ba Subject : RE: Daily 8:15 meeting notes for Wednesday 6/20 CORRECTION TO THE CORRECTION Date: Wednesday, June 20, 2018 12:20:33 PM Hopefully the third time is the charm! There will be cake tomorrow (and it has nothing to do with John Jandovitz) ; we will have cake to celebrate and to wish Kenji and Koji farewell.

Fro m: Riemer, Kenneth Sent: Wednesday, June 20, 2018 10:40 AM To: ALL_R3 <AII_R3@ nrc.gov>

Subject:

RE: Da ily 8:15 meeting notes for Wednesday 6/20 Correction - we'll be celebrating John Jandovitz' retirement with cake next week, not tomorrow. Sorry for implying we're so eager to see him leave that we'll celebrate his retirement without his presence here in the RIii; future congrats to John!!!

Fro m: Riemer, Kenneth Sent: Wednesday, June 20, 2018 10:00 AM To: ALL_R3 <All R3@nrc goy>

Subject:

Dai ly 8:15 meeting notes for Wed nesday 6/20 The Daily Morning Meeting News for Wednesday, June 20, 2018 Regional Duty Officer: K. Riemer Teleconference Number: (800) 779-9565; Passcode:._I_ . .......... _ _.

...J. . .{l?)(?L Note: This newsletter may contain pre-decisional info. Do not distribute outside the NRC.

Behaviors of High Trust Leaders: Confront Reality Take issues head on, even the "undiscussables." Acknowledge the unsaid. Address the tough stuff directly. Confront issues before they turn into major problems. Lead out courageously in conversation. Confront the reality, not the person. Don't skirt the real issues. Don't bury your head in the sand.

Support Issues:

RA: None DRP: Farewell cake tomorrow at 10:00 for John Jandovitz for his retirement!

DRS: 1) 10:00 am KM session by John Bozga on Risk Informed Thi nking , session available via SKYPE or dial-in;

2) ANS test call last night - follow-up on those who didn't receive the call DNMS: 1) Met with state of Indiana on what it takes to become an agreement state

2) Erin Kennedy passed her qual board and is now a qualified licensee reviewer -

Congrats to Erin!

DRMA: None EICS: 1) No enforcement panels or SER PS tomorrow

2) New guidance for SL IV violations with no performance deficiency. The new guidance (for efficiency purposes) will no longer give discretion; NRC will write up the SL IV violation. The change has been discussed with industry (See attached Office of

Enforcement Memo)

PAO: 1) coverage of discussion on First Energy decommissioning funds; 2) localized coverage of Byron property taxes; 3) NEI grid study Materials Events/Issues:

None Reactor Events None Part 21:

None Plant Status BRANCH 1 Clinton: SIT press release to be issued later this week (b)(5) ...---_(,.JJ_ . . I~...,..n.e...........,,.A..,.....r_.n_o J-..d.*

....,,...... -,,---,----,--......,..----,-...,,....,,.....,...-----,,-.,..,..,.....,...-"""=",....,,....------(....

J,.... b )__ :1 (5....

Quad Cities: Both units in a 7 day LCO due to trip of Unit 2 EOG U1 :

(b)(5) U2: I . . I

- - - - 1

...._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (b...._

)(5___.J BRANCH 2 Monticello:

Prairie Island:

U1:

U2:

DC Cook:

U1 :

U2:

BRANCH 3 (b)(5) Braidwood:

. . . L . ... ********-*-

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

(b)(5) m:

U2: (b)(5)

Byron:!

U1 :

U2:

Palisades:

BRANCH 4 Davis-Besse:

Dresden:

(b)(5)

U2 03:

Point Beach :

U1 :

U2:

BRANCH 5 LaSalle: ,...._________________________

(b)(5), (b)(?)( F) c::::::J U1 :

(b}@ , ( b)(7)( F)

U2 :

Perry:

Fermi 2:

NRR:

Additional Support Issues -

Other Issues -

Personnel News -

Daily Notes/ Preliminary Notification -

One Week Look Ahead -

Post 8:15 Meeting Topics -

From: Biemer Kenneth To: Hanna John Cc: Duncan Erjc: carrjngton Kenya: Murray Robert

Subject:

RE: Daily 8:15 meet ing notes for Wednesday 6/ 20 Date: Thursday, June 2 1, 2018 8:39:52 AM (b)(5)

Ken From: Hanna, Joh n Sent: Thursday, June 21, 2018 6:49 AM To: Riemer, Kenneth <Ken net h.Riemer@n rc.gov>

Subject:

RE: Daily 8:15 meeting notes for Wednesday 6/20 Ken, I know that Nick Valos has "the ball" on this one, but I am curious .. . when does the 7 day clock expire?

By the way if for some reason Nick can't cover it, please let me know. (!

Thanks.

John From: Riemer, Kenneth Sent: Wednesday, June 20, 20 18 11:00 AM To: ALL_ R3 <All R3@nrc.gov>

Subject:

Dai ly 8:15 meeting notes for Wed nesday 6/20 The Daily Morning Meeting News for Wednesday, June 20, 2018 Regional Duty Officer: K. Riemer Teleconference Number: (800) 779-9565; Passcode: _!_ _ * * * -** 1- {~)(?)

Note: This newsletter may contain pre-decisional info. Do not distribute outside the NRC.

Behaviors of High Trust Leaders: Confront Reality Take issues head on, even the "undiscussables." Acknowledge the unsaid. Address the tough stuff directly. Confront issues before they turn into major problems. Lead out courageously in conversation. Confront the reality, not the person. Don't skirt the real issues. Don't bury your head in the sand.

Support Issues:

RA: None DRP: Farewell cake tomorrow at 10:00 for John Jandovitz for his retirement!

DRS: 1) 10:00 am KM session by John Bozga on Risk Informed Thinking , session available via SKYPE or dial-in;

2) ANS test call last night - follow-up on those who didn't receive the call DNMS: 1) Met with state of Indiana on what it takes to become an agreement state

2) Erin Kennedy passed her qual board and is now a qualified licensee reviewer -

Congrats to Erin!

DRMA: None EICS: 1) No enforcement panels or SER PS tomorrow

2) New guidance for SL IV violations with no performance deficiency. The new guidance (for efficiency purposes) will no longer give discretion; NRC will write up the SL IV violation. The change has been discussed with industry (See attached Office of Enforcement Memo)

PAO: 1) coverage of discussion on First Energy decommissioning funds; 2) localized coverage of Byron property taxes; 3) NEI grid study Materials Events/Issues:

None Reactor Events None Part 21:

None Plant Status BRANCH 1 Clinton: SIT press release to be issued later this week (b)(5) Duane Arnolcl: L Quad Cities: Both units in a 7 day LCO due to trip of Unit 2 EOG U1 :

(b)(5)

BRANCH 2 Monticello :

Prairie Island:

U1 :

U2:

DC Cook:

U1 :

U2:

(b)(5)

BRANCH 3 Braidwood: ------------------------------,

U1 :

U2:

(b)(5) ,.!B:z:y~ro~n~

1---iiiiiiiiii--~~;;;;;;;;;;;;;;;;;;;;~;;;;;;;;;;;;;;;;;;;;:;__ _ _ _ _ _ _ _ _ _ _ ____J I U1:

(b)(5)1 U2:

Palisades:

BRANCH 4 Davis-Besse:

Dresden: . - - - - - - - - - - - - - - - - - - - - - - - - - - - - .

(b)(5) ********-- . . ..U2: ............

U3:

Point Beach:

U1 :

U2:

(b)(5), (b)(7)(F)

BRANCH 5 LaSalle:

c:::J U1 :

{ b)(:;i), (b)(7)(F)

U2:

Perry:

Fermi 2:

NRR:

Additional Support Issues -

Other Issues -

Personnel News -

Daily Notes/Preliminary Notification -

One Week Look Ahead -

Post 8:15 Meeting Topics -

From: Kozak Laura To: Biemer Kenneth: Lara Julio: Stoedter Karla: Louden Patrick Cc: Hanna John

Subject:

FW: Clinton SIT Status Date: Friday, June 29, 2018 12:27:56 PM FYI - a good summary from Jeff on our initial thoughts on the SOP evaluation for the Clinton finding.

We will need to prepare for an IFRB and a planning SERP (since HQ takes the lead on shutdown issues). I highlighted several important statements below.

I have typically estimated 4 to 6 weeks for a DRE, this one may be more like 6 to 8 weeks.

From: Mitman, Jeffrey Sent: Thursday, June 28, 2018 7:28 PM To: Fong, CJ <CJ.Fong@nrc.gov>

Cc: Circle, Jeff <Jeff.Circle@nrc.gov>; Kozak, Laura <Laura. Kozak@nrc.gov>

Subject:

Clinton SIT Status (b )(5)

(b)(5)

As a remi nder I'm on ...

l(b_)_(6_)_ ___.I However, If you need to ta lk, we can make arra ngements.

Jeff Mitma n

From: Murray Robert To: Phillips Charles

Subject:

charter items Date: Thursday, June 28, 201 8 2:56:02 PM

5. Understand whether there were any deficiencies in operator training (both licensed and nonlicensed operators) which contributed to the EOG unavailability and the failure to identify the condition across multiple operating shifts. Murray (b)(5)

7. Evaluate licensee planned and completed corrective actions following the EOG event to the extent possible and assess if prior opportunities (e.g., surveillances, maintenance, and self or nuclear oversight assessments) existed to have identified the problem at an earlier point in time. Murray Corrective actions:

(b)(5)

From: Murray Robert To: Phillips Charles Subject : operability comments Date: Thursday, June 28, 2018 2:56:49 PM Non Responsive

Non Responsive IMC 0326 03 .07 Operability Declaration : An operability declaration is a decision by a senior licensed operator on the operating shift crew that there is a reasonable expectation that an SSC can perform its specified safety function.

From: Murray Robert To : Phillips Charles Subject : rou nd point tab le Date: Friday, June 29, 2018 11:10:38 AM Attachments: Rounds Points Grit V.docx boom

(b)(5)

From: Mccraw Aaron To: ALL.Ba

Subject:

The Daily Morning Meeting News for Friday, June 29, 2016 Date: Friday, June 29, 2018 10:05:23 AM Attachments: Dailv Morning Meeting News 06-29-2018.doc)(

The Daily Morning Meeting News for Friday, June 29, 2018 Regional Duty Officer (630.917.8455): Aaron Mccraw.-------.

Teleconference Number: (800) 779-9565; Passcode:! !.JPX?.L Note: This newsletter may contain pre-decisional info. Do not distribute outside the NRG.

Behaviors of High Trust Leaders: Clarify Expectations Disclose and reveal expectations. Discuss them. Validate them . Renegotiate them if needed and possible. Don't violate expectations. Don't assume that expectations are clear or shared.

Support Issues:

RA: Jack Giessner is acting RA today.

DRP: 1) Survey for feedback on Regional Counterpart meeting is open. You can find the survey here: https://www.surveymonkey.com/r/D6XL9BM

2) Please respond to Ann Marie's e-mail regarding service life training. Use vote buttons to indicate your attendance at the previous session so she can gauge the need for makeup session(s).

DRS:

DNMS: Starting Monday, July 2, Jack will be rotating to Region I as the Deputy RA. Good luck, Jack!

DRMA:

EICS: Biannual audit of allegation program was completed yesterday. Region Ill earned high marks. Special thanks to our hardworking EICS staff, but thanks to all who contribute to program's success STATES:

PAO: HAPPY FRIDAY!!! See NBC in the News Today, plus First Energy has offered buyouts to approximately soo corporate office employees.

Materials Events/Issues:

Reactor Events:

Part 21 :

Plant Status BRANCH 1 - Hot weather alerts Clinton: 1) Special Inspection (SIT) for the Emergency Diesel Generator exit today.

2) Today is site's Take Your Kid to Work Day DAEC:

Quad Cities: Ribbon cutting ceremony for new training building today; media expected to be on site, no planned interactions with resident inspectors.

BRANCH 2 DC Cook: 1) Hot weather alert; 2) Monitoring dose rates on recently loaded cask, DNMS is aware.

Prairie Island: Number of Minnesota state reps on site for tour/outreach, no planned interaction with resident inspectors.

Monticello:

BRANCH 3

Byron: Hot weather alert Braidwood: 1) Hot weather alert; 2) Maintenance complete and systems restored.

Palisades:

BRANCH 4

~:;~:; ----*********J:>g~j~* * *~.~.~~=;** ',--** * * -*** ** -*** ** -** * -*----,..1___________________,

. Point Beach : Might get up to 80° - toasty!!!

Dresden : Monitoring lake temps - currently 85°, can operate up to 90° for limited time ,

95° is absolute limit.

BRANCH 5 - Hot weather alerts Fermi:

LaSalle:

Perry: Depending on weather, may have to derate to 86% due to cooling tower efficiency NRR:

Additional Support Issues -

Other Issues -

Personnel News -

Daily Notes/Preliminary Notification - will determine if one is needed for Clinton exit One Week Look Ahead -

Post 8:15 Meeting Topics -

The Daily Morning Meeting News for Friday, June 29, 2018 Regional Duty Officer (630.917.8455): Aaron McCraw (b )(6) !(b)(5)

Teleconfere nce Number: (800) 779-9565; Passcodel..__-_-_-_!':- - -

I Note: This newsletter may contain pre-decisional info. Do not distribute outside the NRC.

Behaviors of High Trust Leaders: Clarify Expectations Disclose and reveal expectations. Discuss them. Validate them. Renegotiate them if needed and possible.

Don't violate expectations. Don't assume that expectations are clear or shared.

Support Issues:

RA: Jack Giessner is acting RA today.

DRP: 1) Survey for feedback on Regional Counterpart meeting is open. You can find the survey here:

https://www.surveymonkey.com/r/D6XL9BM

2) Please respond to Ann Marie's e-mail regarding service life training. Use vote buttons to indicate your attendance at the previous session so she can gauge the need for makeup session(s).

DRS:

DNMS: Starting Monday, July 2, Jack will be rotating to Region I as the Deputy RA. Good luck, Jack!

DRMA:

EICS: Biannual audit of allegation program was completed yesterday. Region Ill earned high marks.

Special thanks to our hardworking EICS staff, but thanks to all who contribute to program's success STATES:

PAO: HAPPY FRIDAY!!! See NRC in the News Today. plus First Energy has offered buyouts to approximately 600 corporate office employees.

Materials Events/Issues:

Reactor Events:

Part 21 :

Plant Status BRANCH 1 - Hot weather alerts Clinton: 1) Special Inspection (SIT) for the Emergency Diesel Generator exit today. 2) Today is site's Take Your Kid to Work Day DAEC:

Quad Cities: Ribbon cutting ceremony for new training building today; media expected to be on site, no planned interactions with resident inspectors.

BRANCH 2 DC Cook: 1) Hot weather alert; 2) Monitoring dose rates on recently loaded cask, DNMS is aware.

Prairie Island: Number of Minnesota state reps on s ite for tour/outreach, no planned interaction with resident inspectors.

Monticello:

BRANCH 3 Byron: Hot weather alert Braidwood: 1) Hot weather alert; 2) Maintenance complete and systems restored.

Palisades:

BRANCH 4 (b)(5)

!(b)(5)

Davis Besse:

Point Beach: Might get up to 80'

toasty!!!

Dresden: Monitoring lake temps - currently 85°, can operate up to 90' for limited time, 95' is absolute limit.

BRANCH 5 - Hot weather alerts Fermi:

LaSalle:

Perry: Depending on weather, may have to derate to 86% due to cooling tower efficiency NRR:

Additional Support Issues -

Other Issues -

Personnel N ews -

Dally Notes/Preliminary Notification - will determine if one is needed for Clinton exit One Week Look Ahead -

Post 8:15 Meeting Topics -

From: Murray Robert To: Louden Patrick Cc: Lara Juno: Karla stoedter /Kaela stoedter@nrc gay) : Riemer Kenneth: Phillips Charles: Draper Jason: ~

Santiago Elba: Sargis Daniel ; Kozak Laura: Stone AnnMarie

Subject:

Clinton SIT Discussion - Licensee Identified Date: Monday, July 02, 2018 1 :09:00 PM Pat/ All-During the SIT exit last week, the licensee had asked about credit for some of the findings that we exited. I wanted to share some of my thoughts on the discussion as we are considering the licensee's f eedback.

Consider the following definitions and discussion related to credit for identification.

Definitions from 0612:

03.05 Licensee-Identified. Licensee-identified findings and violations are (1) identified as a result of deliberate observation by licensee personnel ; and (2) entered into the licensee corrective action program. Examples of deliberate observations that result in licensee-identified findings or violations include (1) those identified during activities such as post maintenance testing, operator rounds, engineering walkdowns, drills, critiques, or audits; and (2) degraded conditions identified during testing which do not result in test failure.

03.09 NRG-Identified. NRG-identified findings or violations are found by NRC inspectors, of which the licensee was not previously aware or had not been previously documented in the licensee's corrective action program. NRG-identified findings or violations also include issues initially identified by the licensee to which the inspector has identified inadequacies in the licensee's characterization or evaluation of the issue of concern.

03. 17 Self-Revealed. Self-revealed findings or violations are those identified as a result of a condition that (1) become apparent through a readily detectable degradation in material condition, capability, or functionality of equipment or plant operations; and (2) does not meet the definition of licensee-identified or NRC-identified . Examples of self-revealed findings or violations include those revealed through: unplanned reactor trips and secondary plant transients; obvious equipment and piping failures; failed on demand testing ; valid plant or electronic dosimeter alarms; ident ification of large quantities of fluids in areas where one would not normally expect such a condition.

From IMC 0612, Appendix B Block 5 Is the finding lice nsee-identified? In determining whether a finding is licensee-identified, NRG-identified, or self-revealing, a measure of subjectivity is anticipated and accepted. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

(b)(5)

(b )(5)

Sincerely, Rob

From : Murray Robert To : Murray Robert Subject : documents Date: Monday, July 02 , 2018 10:53 :50 AM Attachments: charter items.dJiCX ooerat oc rouods.dQcx Rounds Points Ceil V docx attached

5. Understand whether there were any deficiencies in operator training (both licensed and nonlicensed operators) which contributed to the EDG unavailability and the failure to identify the condition across multiple operating shifts. Murray (b)(5)

7. Evaluate licensee planned and completed corrective actions following the EDG event to the extent possible and assess if prior opportunities (e.g., surveillances, maintenance, and self or nuclear oversight assessments) existed to have identified the problem at an earlier point in time. Murray (b)(5)

(b)(5)

The inspectors identified a performance deficiency for the licensee's failure to perform operator rounds and general area checks in accordance with procedure OP-M-102-102, "General Area Checks and Operator Field Rounds," Revision 15, which states, in part:

3.2 Equipment Operators (EOs) are responsible for:

3.2.5. Validating parameters through multiple, independent means, avoiding undue focus on any single indicator.

4.4.4. PERFORM the General Area Checks while conducting rounds. Area checks may include, but are not limited to the following :

- Gauges, meters, and indications within normal bands 4.4.7. PERFORM Equipment Checks to monitor equipment condition. Equipment checks may include, but are not limited to the following:

- Suction, discharge, and recirculation flowpaths available

- Suction and disclharge pressure normal 4.4.8. PERFORM the Operator Field Rounds.

1. VALIDATE parameters through multiple, independent means, avoiding undue focus on any single indicator ...

Contrary to the above, from May 11-17, 2018, five separate equipment operators performed operator rounds in the DG 2 room on at least 12 occasions, and failed to perform equipment checks to monitor equipment conditions by validating parameters using multiple independent means. Specifically, equipment operators failed to identify two diesel generator air start isolation valves were in the closed position (air start flow path), in addition to failing to identify multiple downstream air pressure indications, on two separate local diesel control panels, was not within the normal band.

Inspectors determined this issue was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Confiiguration Control and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e.,

core damage).

The inspectors evaluated the significance of the findiing using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 3, Mitigating Systems, and determined the finding screened as having very low safety significance (Green).

The inspectors did not identify a violation of regulatory requirements associated with this finding.

(b)(5)

From : Kozak Laura To : stoedter Karla: Phillips Charles Cc : Riemer Kenneth Subject : IFRB for Clinton Date: Monday, July 02 , 2018 11 :23:44 AM Attachments: ~

Chuck, Karla Attached is a draft IFRB form for Cli nton. We will need an IFRB and a plann ing SERP.

Can we shoot for an IFRB next week?

I filled in the portions related to the SDP screening and the detailed risk evaluation, the branch will need to fi ll in the info about the PD , etc.

I would like to run th is past Jeff Mitman early next week, so when you complete the form, can you send it back to me for final ed its.

Thanks Laura

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Clinton Click here to enter text.

Docket Number(s): EA Number: EA-Click here to enter text.

Click here to enter text.

Responsible Inspection Branch/Sponsor: Click here to enter text.

(b)(5)

Issue Date: l(b )(S) Exh1-1 0609.0STP

(b)( 5)

Exh1-2 0609.0STP

(b)(5)

Issue Date: ~ Exh1-3 0609.0STP

(b)(5)

Exh1-4 0609.0STP

(b )(5)

Issue Date: ~ Exh1-5 0609.0STP

(b)(5)

Issue Date: ~ Exh1-6 0609.0STP

(b )(5)

Issue Date: El Exh1-7 0609.0STP

(b)(5)

Issue Date: l(b)(S) Exh1-8 0609.0STP

Issue Date: ~ Att1-1 0609.0STP From: Murray Robert To: Stone AnnMarie Subject : RE: Clinton SIT Discussion - Licensee Identified Date: Monday, July 02, 2018 3:29:00 PM Attachments: documents.msg Thanks, AnnMarie. Maybe Chuck can brief you and Karla, together, on Thursday or Friday when she is back in the office. He may be able to shed more light on what I am referring to.

I can also talk with you more on Friday -I *** * * * * * **** ***** . . . . . . . IJ~)(?)

See attached for my draft finding notes from the exit.

Rob From: Stone, AnnMarie Sent: Monday, July 02, 2018 3:13 PM To: Murray, Robert <Robert.M urray@ nrc.gov>

Subject:

RE : Clinton SIT Discussion - Licensee Identified

Rob, Your insights below are spot on. I am interested in the specifics of the findings - perhaps I can assist with the Id credit.

Ann Marie From: Murray, Robert Sent: Monday, July 02, 2018 1:09 PM To: Louden, Patrick <Patrick.Louden@nrc.gov>

Cc: Lara, Julio <Julio.Lara@nrc.gov>; Stoedter, Karla <Karla.Stoedter@nrc.gov>; Riemer, Kenneth

<Kenneth.Riemer@nrc.gov>; Phillips, Charles <Charles.Phillips@nrc.gov>; Draper, Jason

<Jason Draper@nrc gov>; Sa nchez Sant iago, Elba <Elba.SanchezSantiago@nrc.gov>; Sa rgis, Daniel

<Daniel.Sargis@nrc.gov>; Koza k, Laura <Laura.Kozak@nrc.gov>; Stone, Ann Marie

<AnnMarie.Stone@nrc.gov>

Subject:

Clinton SIT Discussion - Licensee Identified Pat/ All-During the SIT exit last week, the licensee had asked about credit for some of the findings that we exited. I wanted to share some of my thoughts on the discussion as we are considering the licensee's feedback.

Consider the following definitions and discussion related to credit for identification.

Definitions from 0612:

03.05 Licensee-Identified. Licensee-identified findings and violations are (1) identified as a result of deliberate observation by licensee personnel ; and (2) entered into the licensee corrective action p rogram. Examples of deliberate observations that result in

licensee-identified findings or violations include (1) those identified during activities such as post maintenance testing, operator rounds, engineering walkdowns, drills, critiques, or audits; and (2) degraded conditions identified during testing which do not result in test failure.

03.09 NRG-Identified. NRG-identified findings or violations are found by NRC inspectors, of which the licensee was not previously aware or had not been previously documented in the licensee's corrective action program. NRG-identified fi ndings or violations also include issues initially identified by the licensee to which the inspector has identified inadequacies in the licensee's characterization or evaluation of the issue of concern.

03.17 Self-Revealed. Self-revealed findings or violations are those identified as a result of a condition that (1) become apparent through a readily detectable degradation in material condition, capability, or functionality of equipment or plant operations; and (2) does not meet the definition of licensee-identified or NRC-identified. Examples of self-revealed findings or violations include those revealed through : unplanned reactor trips and secondary plant transients; obvious equipment and piping failures; failed on demand testing ; valid plant or electronic dosimeter alarms; identification of large quantities of fluids in areas where one would not normally expect such a condition.

From IMC 0612, Appendix B Block 5 Is the finding licensee-identified? In determining whether a findi ng is licensee-identified, NRG-identified , or self-revealing, a measure of subjectivity is anticipated and accepted. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

(b)(5)

Sincerely, Rob

From: Murray, Robert Sent: Mon, 2 Jul 2018 15:53:48 +0000 To: Murray, Robert

Subject:

documents Attachments: operator rounds.docx, Rounds Points Crit V.docx attached

The inspectors identified a performance deficiency for the licensee's failure to perform operator rounds and general area checks in accordance with procedure OP-M-102-102, "General Area Checks and Operator Field Rounds," Revision 15, which states, in part:

3.2 Equipment Operators (EOs) are responsible for:

3.2.5. Validating parameters through multiple, independent means, avoiding undue focus on any single indicator.

4.4.4. PERFORM the General Area Checks while conducting rounds. Area checks may include, but are not limited to the following :

- Gauges, meters, and indications within normal bands 4.4.7. PERFORM Equipment Checks to monitor equipment condition. Equipment checks may include, but are not limited to the following:

- Suction, discharge, and recirculation flowpaths available

- Suction and disclharge pressure normal 4.4.8. PERFORM the Operator Field Rounds.

1. VALIDATE parameters through multiple, independent means, avoiding undue focus on any single indicator ...

Contrary to the above, from May 11-17, 2018, five separate equipment operators performed operator rounds in the DG 2 room on at least 12 occasions, and failed to perform equipment checks to monitor equipment conditions by validating parameters using multiple independent means. Specifically, equipment operators failed to identify two diesel generator air start isolation valves were in the closed position (air start flow path), in addition to failing to identify multiple downstream air pressure indications, on two separate local diesel control panels, was not within the normal band.

Inspectors determined this issue was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Confiiguration Control and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e.,

core damage).

The inspectors evaluated the significance of the findiing using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 3, Mitigating Systems, and determined the finding screened as having very low safety significance (Green).

The inspectors did not identify a violation of regulatory requirements associated with this finding.

(b)(5)

From: Mitman Jeffrey To: Circle Jeff: E2rJg,._CJ Cc: Kozak Laura

Subject:

RE: Clinton SIT Status Date: Tuesday, July 03, 2018 5:53:27 PM

Jeff, To the best of my recollection, the system lineups were all normal for shutdown cond itions with the obvious exception that TS requires an operable EDG during most configurations. Clinton did not meet this requirement for a period of slightly more than 3 days.

Jeff Mitman From: Ci rcle, Jeff Sent: Friday, June 29, 2018 5:23 AM To: M it ma n, Jeffrey <Jeffrey. M it ma n@nrc.gov>; Fong, CJ <CJ.Fong@nrc.gov>

Cc: Kozak, La ura <Laura.Kozak@nrc.gov>

Subject:

RE: Clinton SIT Status

Jeff, Tha nks for the summa ry. As you mentioned earlier, this finding is an excellent ment oring opportunity for you. We can talk after you and CJ both get back from leave after next week. This finding will be a chal lenge. During the exposure t ime period, did you not ice any unusual system alignments t hat would cause a signif ica nt change in risk?

After you get back, I'll be back in the office on Tuesday 7/10/18.

Jeff.

From: M itman, Jeffrey Sent: Thursday, June 28, 2018 8:28 PM To: Fong, CJ <CJ.Fong@nrc.gov>

Cc: Circle, Jeff <Jeff Cjrcle@nrc gov>; Koza k, Laura <Laura Kozak@nrc gov>

Subject:

Clinton SIT Status (b )(5)

(b )(5)

I As a remi nd er I'm on._!_ _......,._..... However, If you need to ta lk, we can make arrangements.

(b)(6)

Jeff M itma n

Note to requester: The attachment to this email has been withheld in its entirety under FOIA Ex. B5 (deliberative process privilege).

From: Kozak Laura To : Phillips Charles Cc : Mitman Jeffrey : StaedJer Karla Subject : SDP phase 1 and 2 for the inspection report Date: Tuesday, Ju ly 03 , 2018 10:11 :23 AM Attachments: phase 2 SDP input ta report.docx Chuck Please see attached. I drafted the SDP phase 1 and 2 discussion for the report input.

Please review and discuss any necessary changes. Jeff - if you have any comments please let me know.

I drafted this assuming we issue the report significance "TBD" given that we are planning to perform a phase 3 SDP evaluation. We often choose not to issue reports until the phase 3 SDP is complete, so if we choose another path , th is write-up will need to change. But I wanted to you have it if we move forward with what was exited last week.

Laura

(b )(5)

(b)(5)

Note to requester: The fi rst 3 attachments to this email are withheld in their entirety under FOIA Ex. B5 (deliberative process priviledge). The 4th attachment is From : Kozak Laura a non-responsive record due to clarifying the request to To : Mitman Jeffrey exclude licensee oriainated documents .

Subject : Clinton Date: Thursday, July 05 , 2018 12 :37 :00 PM Attachments: LQQESQJ)mo, Qb_s_ervaho.ns on cros.s1i.e. docx.

CALCULATION NUMBER A 1 13 - Div 3 cross tie CPS PAA 2014 docx DB430301 -04 4303 01 - Exte nsive Damage Mitigation Guide (B s b) SHORTENED Page 62on potx Jeff

( b )(5)

Laura

From: Kozak Laura To: Arner Frank: Hanna John: Macdonald George: Yalos Nicholas: Deese Rick: Loveless David: Freeman Scou Cc: Mitman Jeffrey Subject : RE: FW: Follow-up to FLEX meeting from yesterday Date: Thursday, July 05, 2018 8 :00:25 AM Thanks for sharing Frank.

Jeff Mitman and I are working on a shutdown issue at Clinton where both EDGs were unavailable. FLEX is going to play a role and the licensee is already claiming E-3 failure rates.

From: Arner, Fra nk Se nt: Thursday, Ju ly 05, 2018 7:30 AM To: Hanna, John <John.H anna @nrc.gov>; M acdona ld, George <George.MacDona ld@nrc.gov>;

Kozak, La ura <Laura.Kozak@nrc.gov>; Valos, Nicholas <Nicholas.Valos@nrc.gov>; Deese, Rick

<R ick.Deese@nrc.gov>; Loveless, David <David.Loveless@nrc.gov>; Freeman, Scott

<Scott.Freema n@nrc.gov>

Subject:

FW: FW: Follow-up to FLEX meeting from yesterday Just FYI, we've seen when we've asked for start data (success vs. failures) in some cases very elevated failure rates for FLEX equipment. I'm also aware of several licensees already incorporating FLEX directly into their models with failure rates to start in the area of 1E-3.

Let's just say I'm very skeptical of any failure rates being applied, especially given this recent insight from one Licensee contacting EPRI where EPRI has basically transferred the ball to the owners groups. I'm not even sure the equipment failure rates even given N+ 1, wouldn't be equivalent or higher than human error probabilities at this point.

From Hope Creek representatives contacting EPRI:

I spoke to the EPRI FLEX database people after our meeting. EPRI has received requests to use the FLEX database information to develop FLEX component fai lure rates; however, EPRI determ ined that t he data, in its current form, was not adequat e to develop accurate component failure rates. Last month they tu rned over t he task to the PWR and BWR owner's groups. The owner's groups have the action to develop the controls necessary to accurately gather t he information for developing failure rates. The EPRI person that I spoke to did not have a timeline for the owner's groups action F

From: Arner, Frank Se nt: Thursday, Ju ly 05, 2018 8:18 AM To: Monteca lvo, Michael <Mjchael,Monteca lvo@nrc.gov>; Helton, Dona ld

<Dona ld.Helton@nrc.gov>; Fong, CJ <O.Fong@nrc.gov>; Circle, Jeff <Jeff Circle@nrc gov>

Cc: Humberstone, Matt hew < Matthew Humberstone@nrc.gov>

Subject:

RE: FW: Fol low- up to FLEX meeting from yesterday Fair enough comment Mike, as I'm not one to have been a big proponent of making that

(b)(5) push to Maintenance Rule requirements regarding FLEX. I I

{b)(5)

F From: Montecalvo, Michael Se nt: Thursday, July 05, 2018 8:09 AM To: Arner, Frank <Frank.Arner@nrc.gov>; Helton, Dona ld <Dona ld Helton@nrc.gov>; Fong, CJ

<CJ Fong@ nrc gov>; Circle, Jeff <Jeff Circle@nrc gov>

Cc: Humberstone, Matt hew <Matthew.Humberstone@nrc.gov>

Subject:

RE: FW: Follow-up to FLEX meet ing from yesterday This seems to be a common misconception that needs to be cleared up, we did not agree to a blanket "out" for not scoping FLEX into the MR. The scoping is based on the use of the equipment, just as it always has been and how it is done for any other piece of equipment.

In fact, if you look at the current revision we put additional restrictions on what the licensee can do when they are using FLEX equipment as an additional defense in depth measure.

The reg guide endorsing the 4f revision to NUMARC 93-01 is in the concurrence process right now and should be going out for public comment soon, if it hasn't already.

Mike From: Arner, Frank Sent: Friday, June 29, 2018 10:20 AM To: Helton, Donald <Donald Helton@nrc gov>; Fong, o <CJ Fong@nrc gov>; Circle, Jeff

<Jeff Circle@nrc gov>; Montecalvo, Michael <Michael Montecalvo@nrc gov>

Subject:

RE: FW: Follow-up to FLEX meeting from yesterday Any presentation developed for the DDCM meeting, in my opinion should include or incorporate the severity of uncertainty that seems to exist with this equipment - especially in the realm of reliability of the equipment based on actual test data. tie path of not incorporating FLEX into the MR has made th is that much more of a question mark.

F From: Arner, Frank Se nt: Friday, June 29, 2018 10:18 AM

To: Helt on, Donald <Donald.Helton@nrc.gov>; Fong, o <CJ.Fong@nrc.gov>; Circle, Jeff

<Jeff Cirde@nrc gov>; M ontecalvo, M ichael <Michae l. Monteca lvo@nrc.gov>

Subject:

FW: FW: Follow -up t o FLEX meeti ng from yesterday I am forwarding this to ensure you are all aware (you probably are) with the difficulties the industry is apparently having in gathering FLEX equipment reliability data. I know having led 4 or 5 of the Tl 191 inspections, the failure rates for start are much.much higher than 1 in 1000 for this equipment based on actual attempts and failures seen that have been documented within the CA program. I also am aware Licensee's have already began incorporating FLEX equipment into their models with failure to start rates of 1E-3. I do believe in FLEX credit but l"m still an advocate of keeping it simple, (for example a top mitigating box at the end of SBO sequences with FLEX - using a 0.1 or 0.2 value only in sequences where FLEX can succeed .... successful DEP, Load Shedding, Containment Venting if applicable.

From: Hawkins, Justin Sent: M onday, June 18, 2018 4 :21 AM To: Arner, Frank <Frank,Arner@nrc.gov>

Subject:

FW: FW: Follow-up t o FLEX meet ing from yesterday For awareness. PSEG responded to my FLEX reporting questions. Let me know if this sounds appropriate to you .

From: Hawkins, Just in [mailto *Justjn Hawkjns@pseg com]

Sent: M onday, June 18, 2018 4 :20 AM To: Hawkins, Justin <Justin Hawkios@nrc gov>

Subject:

[External_Sender] FW: Follow-up to FLEX meet ing from yest erday LJ LJ LJ LJ From: Koppel, Peter J.

Sent: Friday, June 15, 2018 7:36 AM To: Hawkins, Justin ; Timberman, Tanya J; MacEwen, Thomas T.

Cc: Haney, Sherlyn ; Banner, Craig W.; Franklin, Danny; Baker, Joseph W. ; Stith, Gary M.; Dior, Mitchell S.

Subject:

RE: Follow-up to FLEX meeting from yesterday

Justin, I spoke to the EP RI FLEX dat abase people aft er our meeting. EPRI has received request s to use t he FLEX database information to develop FLEX component fai lure rat es; how ever, EPRI determ ined t hat the dat a, in its current form, w as not adequate to develop accurate component fa ilure rates. Last

month they tu rned over the task to the PWR and BWR owner's groups. The owner's groups have the action to develop t he controls necessary t o accurately gather t he information for developing fail ure rates. The EPRI person that I spoke to did not have a timeline for the owner's groups action .

Listed below are t he notifications t hat we have added to t he EPRI FLEX database. The criteria we used was component failures (fail ures to st art or failu res in operation), and anythi ng we (Salem, Hope Creek, Corporate) felt was worthy of sharing with the remainde r of the ind ustry.

Non Responsive

Non Responsive Peter Koppel X2835 From: Hawkins, Justin Sent: Thursday, June 14, 2018 4:29 AM To: Timberman, Tanya J; MacEwen, Thomas T.; Koppel, Peter J.

Cc: Haney, Sherlyn Subject : Follow-up to FLEX meeting from yesterday Tanya, I spoke to Frank Arner (Regional SRA- Senior Risk Analyst) about his concerns regarding FLEX equipment failure reporti ng. Based on this conversation, I would like to see the information that is submitted to the industry (December 2017 and June 2018) and t he criteria for submittal.

Thanks, Justin Hawkins HCSRI X1078 The information contained in this e-mail, including any attachment(s), is intended solely for use by the named addressee(s). If you are not the intended recipient, or a person designated as responsible for delivering such messages to the intended recipient, you are not authorized to disclose, copy, distribute or retain this message, in whole or in part, without written authorization from PSEG. This e-mail may contain proprietary, confidential or privileged informatio n. If you have received this message in error, please notify the sender immediately.

This notice is included in all e-mail messages leaving PSEG. T hank you for your cooperation.

From : Stoedter Karla To : Kozak Laura Subject : Clinton EDG Unavailability IFRB .docm Date: Monday, July 09 , 2018 1 :22 :00 PM Attachments: Clinton EDG Unavailabilitv IFRB .docm

Laura, Here is the current IFRB worksheet for Clinton. I'm still trying to schedule something for Wednesday .

Karla

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Clinton Exelon Docket Number(s): EA Number: EA-Click here to enter text.

50-461 (b)(5)

Issue Date: EJ Exh1-1 0609.0STP

(b)(5)

Issue Date: EJ Exh1-2 0609.0STP

(b )(5)

Issue Date: EJ Exh1-3 0609.0STP

(b)(5)

Issue Date: ~ Exh1-4 0609.0STP

(b )(5)

Issue Date: ~ Exh1-5 0609.05TP

(b )(5)

Issue Date: LJ Exh1-6 0609.0STP

(b )(5)

Issue Date: ~ Exh1-7 0609.0STP

(b)(5)

Issue Date: l(b)(S) I Exh1-8 0609.0STP

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

Issue Date: .__ _.... Exh1-9 0609.0STP

(b)(5)

Issue Date: EJ Exh1-10 0609.0STP

(b)(5)

Issue Date: ~ Exh1-11 0609.0STP

(b)(5)

Issue Date: LJ Exh1-12 0609.0STP

Issue Date: ~ Att1-1 0609.0STP From: Kozak Laura To: fQnQ....Q,!; Arner frank: Montecalvo Michael Cc: Humberstone Matthew: Helton Donald: Circle Jeff: Loveless Dayjd: Deese Rick: Cahill Christopher: F.reemaa.

~ ; Macdonald George: Hanna John: Mitman Jeffrey Subject : RE: FW: Follow-up to FLEX meeting from yesterday Date: Wednesday, July 11, 2018 8:19:13 AM Tha nks for the update CJ. I'm glad this is a priority in NRR. Jeff M and I are working on the Clinton issue which wi ll need to consider FLEX. I find it is much more complicated than just "adding" cred it t o the model for Flex, whet her it be .1, .3, or E-3 (as the licensee is suggesting).

Our issue is a shutdown issue. The generic Appendix G model credits the use of an installed DD fire pump for injection with recovery of offsite power if SBO occurs. This is given quite a bit of cred it.

What we fi nd whe n we go to t he site is t hat in all likelihood t his is not the strategy t hat would be used and if the preferred strategies fail (FLEX or Division 3 cross tie), it is unl ikely for the "old" strategy to work. Yet, I find it hard to believe that the new strategies will be as reliable as the generic assumptions in the Append ix G event tree.

The licensee has suggested that the fi rst preferred strategy would be to use t he Division 3 crosstie.

Maybe that is true. But if it is, that has implications for compliance with the Order, as the scenario portrayed by the order does not postulate other failures, mean ing Division 3 would be avai lable.

Yet, the licensee told us t hey would declare ELAP, enter FLEX procedures, and discontinue the use of other procedu res in all of the responses to the new requirement. Now, in this SOP evaluation, t hey seem to be saying something different.

Both implementing the cross-tie or FLEX have implications for recovery of OSP and the EOG (both less li kely to be successful) arnd t here is some dependency between the cross-tie and FLEX that must be considered.

The positives about Cli nton are that a diese l was recoverable and the exposure time is short.

Laura From: Fong, CJ Sent: Wednesday, July 11, 2018 7:23 AM To: Arner, Fran k <Frank.Arner@nrc.gov>; Montecalvo, Michael <M ichael. Montecalvo@nrc.gov>

Cc: Hu mberstone, Matthew <Matthew.Humberstone@nrc.gov>; Helton, Donald

<Dona ld.Helton@nrc.gov>; Circle, Jeff <Jeff.Circle@nrc.gov>; Loveless, David

<David.Loveless@nrc.gov>; Deese, Rick <Rick.Deese@nrc.gov>; Kozak, Laura

<Laura.Kozak@n rc.gov>; Cahi ll, Christopher <Christopher.Ca hi ll@nrc.gov>; Freeman, Scott

<Scott.Freeman@nrc.gov>; M acdona ld, George <George.MacDona ld@nrc.gov>; Hanna, John

<John.Hanna@nrc.gov>

Subject:

RE: FW: Fol low-up to FLEX meeting from yesterday No problem, Frank. FYI, I view the development of a practical, technically-credible, transparent FLEX approach for oversight (including SDPs, NOEDs) as one of APHB's top priorities. Matt and Mike are doing an excellent job managing this project, especially

considering the fact that the EPRl-industry data collection effort failed open.

I'm cautiously optimistic that the reboot of the data collection initiative (with PWROG now in control) will be successful but we need to maintain focus and constant engagement with industry on this topic. To that end, I have discussed this with the NRR Deputy Office Director and I have placed this on the agenda for the upcoming meeting with the BWROG senior management and our SESers. I will also be meeting with the PWROG in August to ascertain their progress on this issue. I'll keep you posted.

Thanks, f!97~- 'P &.

Chief , PRA Operations and Human Factors Branch (APHB)

Div ision of Risk Assessment Office of Nuclear Reactor Regulation (30 1) 415- 8474 From: Arner, Frank Sent: Wednesday, July 11, 2018 7:09 AM To: Fong, CJ <CJ Fong@nrc gov>; Montecalvo, Michael <Michael Montecalvo@nrc gov>

Cc: Humberstone, Matthew <Matthew Humberstone@nrc gov>; Helton, Donald

<Dona ld.Helton@nrc.gov>; Circle, Jeff <Jeff.Cjrcle@nrc.gov>; Loveless, David

<David Loveless@nrc gov>; Deese, Rick <Rick.Deese@nrc.gov>; Kozak, Laura

<Laura Kozak@nrc gov>; Cahill, Christopher <ChrjstoRher Cah ill@orc gov>: Freeman, Scott

<Scott Freeman@nrc.gov>; Macdonald, George <George MacDonald@nrc gov>; Hanna, John

<John.Hanna@nrc.gov>

Subject:

RE : FW: Fol low-up to FLEX meet ing from yest erday Excellent info, thanks for the update CJ. This should serve to address this important topic.

I have used sensitivity studies before in SDPs with an event sequence END FLEX box turned on and off as desired, only applied in sequences which support the FLEX strategy.

This ends up not quite being 0.1 credit, more like 0.17 in some cases, because it can only be applied in the proper sequences (i.e DEP successful, DC load strip successful, CV etc ...

I agree with this more basic strategy for now.

F From: Fong, CJ Sent: Monday, July 09, 2018 8:04 AM

To: Arner, Fran k <Frank Arner@nrc gov>; Montecalvo, Michael <Michael Montecalvo@nrc gov>

Cc: Humberstone, Matt hew <Matthew.Humberstone@nrc gov>; Helton, Donald

<Dona ld Helton@nrc gov>; Circle, Jeff <Jeff Circle@nrc gov>

Subject:

RE: FW: Fol low-up to FLEX meet ing from yesterday (b )(6)

Hi, Frank. Sorry for the late response; ! IHere's the bottom line:

the data at this point do not support failure rates in the 1E-3 / attempt range. Therefore, as an interim approach, we (the PRA community) need to use screening values (e.g., 0.1) and sensitivity studies. As Mike pointed out, Matt has developed some guidance on how to do this in a consistent and technically-sound manner.

As Mr. Kopel pointed out earlier in the thread, the PWROG has taken over the data gathering and analysis (they're going to do this for both PWRs and BWRs by the way).

believe their approach is a step change improvement from what EPRI attempted.

Specifically, the PWROG will have a multi-disciplinary team (including PRA data people) looking at all work orders* related to FLEX equipment. During my conversations with them, I specifically mentioned the scenarios that you have described in previous e-mails (e.g.,

truck battery used to start FLEX equip) and they assured me that their methodology would screen these events in and would count them as PRA failures. They also stated that recovery actions would be considered separately. In other words, such an event might be treated as a failure but with successful recovery action. They will provide APHB with an update on their progress in late August and have committed to sharing the draft and final results of their analysis with the NRC (although we will need to work out the details . .. .we may want to engage INL on this). Their target is to complete this work by the end of 2018 but they didn't want to make a hard commitment. I have asked them to send us a letter outlining their proposed schedule so that we have something more tangible.

I hope this helps. I think this is a great topic for the DDCM but I want to make sure that we're all on the same page in terms of:

A. How SDPs/NOEDs involving FLEX should be conducted QQW (i.e., given the current lack of FLEX data).

B. The path forward.

Happy to chat if you'd like to discuss further.

Thanks, CJ

The PWROG agreed with your assessment that just looking at CRs might not capture all FLEX-related failures. They believe that looking at work orders will cast a wider net. I can't speak for every site/licensee but this is certainly consistent with my experience at Watts Bar (there was a much lower bar for writing a work order vs. a CR).

From: Arner, Frank

Sent: Thursday, July 05, 2018 9:13 AM To: Monteca lvo, Michael <Michael Montecalvo@nrc.gov>

Cc: Humberstone, Matthew <Matthew.Humberstone@nrc.gov>; Helton, Donald

<Dona ld.Helton@nrc.gov>; Fong, CJ <CJ.Fong@nrc.gov>; Circle, Jeff <Jeff.Circle@nrc.gov>

Subject:

RE: FW: Fol low-up to FLEX meeting from yesterday Agreed ... l'm a FLEX credit advocate for the most part, but certainly not comfortable with the application and failure rates being applied in some of the licensee model updates I'm seeing.

My plan, to get some feel, is to ask for every start attempt in the last few years of key FLEX equipment, and the result as part of a sensitivity to FLEX credit. Many of these issues, (failure of equipment) may not always be entered into the CR system. This gives at least some idea of where a particular plant may stand with reliability with a limited sample.

F From: Montecalvo, Michael Se nt: Thursday, July 05, 2018 8:44 AM To: Arner, Fran k <Frank.Arner@nrc.gov>

Cc: Humberstone, Matt hew <Matthew.Humberstone@nrc.gov>; Helton, Donald

<Dona ld.Helton@nrc.gov>; Fong, CJ <CJ .Fong@n rc.gov>; Circle, Jeff <Jeff.Circle@nrc.gov>

Subject:

RE: FW: Fol low-up to FLEX meet ing from yesterday Point certainly well taken Frank, the operating experience you have shared from the inspections is troubling. The owners groups taking this effort is a step in the right direction, as EPRI was trying to force fit their data collection efforts related to maintenance optimization to component failure rates and having a tough time doing it based on what data was being collected and how it was characterized. The fact that we are this far along with crediting the equipment and actions without reliable data is disappointing, and should be taken into account because it could potentially affect results. As long as we realize where we are with the current state of knowledge, we should still be able to make consistent regulatory decisions. The rules of engagement that Matt put together will help with that.

Mike From: Arner, Frank Sent: Thursday, July 05, 2018 8:18 AM To: Monteca lvo, Michael <Michael Montecalvo@nrc gov>; Helton, Donald

<Dona ld.Helton@nrc.gov>; Fong, CJ <CJ.Fong@n rc.gov>; Circle, Jeff <Jeff.Circle@nrc.gov>

Cc: Humberstone, Matt hew <Matthew.Humberstone@nrc.gov>

Subject:

RE : FW: Fol low-up to FLEX meeting from yesterday Fair enough comment Mike, as I'm not one to have been a big proponent of making that push to Maintenance Rule requirements regarding FLEX. ...... J~)(~)

(b)(5)

F From: Montecalvo, Michael Se nt: Thursday, July 05, 2018 8:09 AM To: Arner, Frank <Frank Arner@nrc gov>; Helton, Dona ld <Dona ld Helton@nrc gov>; Fong, CJ

<CJ Fong@nrc gov>; Circle, Jeff <Jeff Circle@nrc gov>

Cc: Humberstone, Matthew <Matthew Humberstone@nrc gov>

Subject:

RE: FW: Fol low-up to FLEX meeting from yesterday This seems to be a common misconception that needs to be cleared up, we did not agree to a blanket "out" for not scoping FLEX into the MR. The scoping is based on the use of the equipment, just as it always has been and how it is done for any other piece of equipment.

In fact, if you look at the current revision we put additional restrictions on what the licensee can do when they are using FLEX equipment as an additional defense in depth measure.

The reg guide endorsing the 4f revision to NUMARC 93-01 is in the concurrence process right now and should be going out for public comment soon, if it hasn't already.

Mike From: Arner, Frank Sent: Friday, June 29, 2018 10:20 AM To: Helton, Donald <Donald Helton@nrc gov>; Fong, CJ <CJ Fong@nrc gov>; Circle, Jeff

<Jeff Cjrcle@nrc gov>; Montecalvo, Michael <Michael Montecalvo@nrc gov>

Subject:

RE: FW: Fol low-up to FLEX meeting from yesterday Any presentation developed for the DDCM meeting, in my opinion should include or incorporate the severity of uncertainty that seems to exist with this equipment - especially in the realm of reliability of the equipment based on actual test data. lie path of not incorporating FLEX into the MR has made this that much more of a question mark.

F From: Arner, Fra nk Sent: Friday, June 29, 2018 10:18 AM To: Helton, Donald <Donald Helton@nrc gov>; Fong, CJ <CJ Fong@nrc gov>; Circle, Jeff

<Jeff Cjrcle@nrc gov>; Montecalvo, Michael <Michael Montecalvo@nrc gov>

Subject:

FW: FW: Follow-up t o FLEX meet ing from yesterday I am forwarding this to ensure you are all aware (you probably are) with the difficulties the industry is apparently having in gathering FLEX equipment reliability data. I know having led 4 or 5 of the Tl 191 inspections, the failure rates tor start are much,much higher than 1 in 1000 for this equipment based on actual attempts and failures seen that have been documented within the CA program. I also am aware Licensee's have already began incorporating FLEX equipment into their models with failure to start rates of 1E-3. I do believe in FLEX credit but I'm still an advocate of keeping it simple, (for example a top mitigating box at the end of SBO sequences with FLEX - using a 0.1 or 0.2 value only in sequences where FLEX can succeed .... successtul DEP, Load Shedding, Containment Venting it applicable.

From: Hawkins, Just in Sent: M onday, June 18, 2018 4:21 AM To: Arner, Frank <Frank Arner@nrc.gov>

Subject:

FW: FW: Follow-up to FLEX meeting from yesterday For awareness. PSEG responded to my FLEX reporting questions. Let me know if this sounds appropriate to you .

From: Hawkins, Justin [mailto-Justio Hawkios@pseg com]

Sent: M onday, June 18, 2018 4:20 AM To: Hawkins, Justi n <Justin Hawkjns@nrc gov>

Subject:

[Externa l_Sender] FW: Follow-up to FLEX meeting from yesterday LJ LJ LJ LJ From: Koppel, Pet er J.

Sent: Friday, June 15, 2018 7:36 AM To: Hawkins, Justin; Timberman, Tanya J; MacEwen, Thomas T.

Cc: Haney, Sherlyn ; Banner, Craig W.; Franklin, Danny; Baker, Joseph W.; Stith, Gary M.; Dior, Mitchell s.

Subject:

RE: Follow-up to FLEX meeting from yesterday

Justin, I spoke to the EP RI FLEX database people after our meeting. EPRI has received requests to use the FLEX database information to develop FLEX component failu re rates; however, EPRI determ ined that the data, in its current form, was not adequate to develop accurate component fa ilure rates. Last month they tu rned over t he task to the PWR and BWR owner's groups. The owner's groups have the action to develop t he controls necessary to accurately gather t he information for developing

fail ure rates. The EPRI person that I spoke to did not have a timeline for the owner's groups action.

Listed below are t he notifications t hat we have added to t he EPRI FLEX database. The criteria we used was component failures (failures to start or fa il ures in operation), and anythi ng we (Salem, Hope Creek, Corporate) felt was worthy of sharing with the remainder of the industry.

Non Responsive

Non Responsive Peter Koppel X283S From: Hawkins, Justin Sent: Thursday, June 14, 201 8 4:29 AM To: Timberman, Tanya J; MacEwen, Thomas T.; Koppel, Peter J.

Cc: Haney, Sherlyn

Subject:

Follow-up to FLEX meeting from yesterday Ta nya, I spoke t o Frank Arner (Regional SRA- Senior Risk Analyst) ab out his concerns regarding FLEX equipment fa ilure reporti ng. Based on this conversat ion, I would like to see the information t hat is su bmitted to the ind ustry (December 2017 and June 2018) and t he criteria for su bmittal.

Thanks, Justin Hawkins HCSRI X1078 The informatio n contained jn this e-mail, includ ing any attachment(s), .is intended solely for use by the named addressee(s). If you are not the intended recipient, or a person designated as responsible for delivering su ch messages to the intended recipient, you are not authorized to disclose, copy, d istribute or retai n this message, in whole or in part, without written authorization from PSEG. This e-mail may contain proprietary, confidential or privileg ed information. If yo u have received this message in error, please notify the sender immediately.

This no tice is included in all e-ma il messages leaving PSEG. Thank you for your cooperation.

From: Murray Robert To : Phillips Charles Subject : SIT Input Date: Thursday, July 12, 2018 1:11 :00 PM Attachments: fillo~

imaae_0_OJ .ona See attached.

Rob Murray Quad Cities Senior Resident Inspector Office (309)654-2227 (b )(6) .CelL! - - . I 7 U. RC

5. Understand whether there were any deficiencies in operator training (both licensed and nonlicensed operators) which contributed to the EDG unavailability and the failure to identify the condition across multiple operating shifts.

(b)(5)

7. Evaluate licensee planned and completed corrective actions following the EDG event to the extent possible and assess if prior opportunities (e.g., surveillances, maintenance, and self or nuclear oversight assessments) existed to have identified the problem at an earlier point in time.

(b)(5)

(b )(5)

(b)(5)

From: Stoedter Karla To : Louden Patrick : Skokowski Richard : Lambert Kenneth Cc : PhilHps Charles : Sargis Daniel Subject : Clin ton EOG Unavailability IFRB Date: Monday, July 16, 2018 1:27 :00 PM Attachments: Clinton EOG Unavailability IFRB .docm Pat and Rick, Here is the Clinton IFRB worksheet for Thursday. My understanding is the IFRB will be Thursday immediately following the enforcement panel. If you understand differently, please let me know.

Karla

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Clinton Exelon Docket Number(s): EA Number: EA-Click here to enter text.

50-461 (b)(5)

Issue Date: l(b)(S) Exh1-1 0609.0STP

(b)(5)

Issue Date: ~ Exh1-2 0609.0STP

(b )(5)

Issue Date: ~ Exh1-3 0609.0STP

(b)(5)

Issue Date: ~ Exh1-4 0609.0STP

(b )(5)

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(b)(5)

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(b )(5)

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(b)(5)

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(b )(5)

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(b)(5)

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(b )(5)

Issue Date: EJ Exh1-12 0609.0STP

Issue Date: l(b)(S) Att1-1 0609.0STP

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Clinton Exelon Docket Number(s): EA Number: EA-Click here to enter text.

50-461 (b )(5)

Issue Date: !(b)(S) Exh1-1 0609.0STP

(b)(5)

Issue Date: l(b)(S) I Exh1 -2 0609 .0STP

(b)(5)

Issue Date: ~ Exh1-3 0609 .0STP

(b)(5)

Issue Date: LJ Exh1-4 0609 .0STP

(b )(5)

Issue Date: ~ Exh1-5 0609 .05TP

(b)(5)

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(b){5)

Issue Date:~ Exh1-7 0609 .0STP

(b)(5)

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(b)(S)

Issue Date: l(b)(S) I Exh1-9 0609.0STP

(b)(S)

Issue Date: ~ Exh1 -10 0609 .0STP

(b)(S)

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(b)(S)

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(b)(5)

Issue Date: ~ Exh1-13 0609.0STP

Issue Date: ~ Att1 -1 0609.0STP From: Mitman Jeffrey To : Kozak Laura Cc : Montecalvo Michael Subject : Clin ton EOG Unavailabili ty IFRB j tm2 .docm Date: Thursday, July 19, 2018 11 :48:17 AM Attachments: Clinton EOG Unavailability IFRB jtm2.docm Laura, here are my suggested changes.

Jeff Mitman

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee :

Clinton Exelon Docket Number(s): EA Number: EA-Click here to enter text.

50-461 (b)(5)

Issue Date : l(b)( 5) Exh1-1 0609.0STP

(b)(5)

Issue Date : l(b)(S) I Exh1-2 0609.0STP

(b)(5)

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

Issue Date : .__ ___, Exh1-4 0609.0STP

(b)(5)

Issue Date : ~ Exh1 -5 0609.0STP

(b)(5)

Issue Date: EJ Exh1 -6 0609.0STP

(b)(5)

Issue Date : l(b)(S) I Exh1 -7 0609.0STP

(b)(5)

Issue Date: E] Exh 1-8 0609.0STP

(b )(5)

Issue Date: l(b)(S) I Exh1 -9 0609.0STP

(b)(5)

Issue Date: EJ Exh1-10 0609.05TP

(b )(5)

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(b)(5)

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(b )(5)

Issue Date: ~ Exh1-13 0609.0STP

Issue Date: LJ Att1-1 0609.05TP From: Mitman Jeffrey To : ~

Cc : Montecalvo Michael: Ecanovjch Mike: Felts Russell : Kozak Laura: Circle Jett: Helton Donald: Casey Lauren Subject : DECISION REQUIRED : Clinton IFRB Results and Next Actions Date: Thursday, July 19, 2018 2 :03:10 PM Attachments: Clinton $DP Plan 07- 19-18.odt CJ ,

We completed the Cl inton EOG unavailability IFRB today. The IFRB agreed that there is a performance deficiency and directed APHB to continue work on the detail risk evaluation (SOP).

I've committed to complete the DRE by August 29 th _ This will allow sufficient time to complete the required reviews and other process requirements needed to meet the SOP clock due date of ~11/10/18. This is a very tight timeline. It assumes that the DRE shows a greater than 1E-6 CDF. It is expected that the inspection will be re-exited . If this re-exit occurs, then the SOP clock will reset. However, any additional time made available by the clock reset will be used to perform the other required tasks, i.e., not the DRE.

Region Ill plans to conduct a Planning SERP with HQ next Thursday (August 26 th ). A planning SERP is required because HQ has the lead on the DRE instead of Region Ill.

An updated copy of my schedule is attached .

Do you want me to schedule a briefing with ORA management in preparation for the Planning SERP?

Jeff Mitman

ID Task Name Duration % Start Finish IMav June Julv Auaust I Seolember October November Comolete 04/29 I 05/06 I 05/13 I 05/20 I 05/27 I 06103 I 06/1 oI06/17 I 06/24 07/01 I 07/08 I 07/15 I 07/22 I 07/29 I08/05 I 08/12 I08/19 I 08/26 I09/02 I 09/09 I 09/16 I 09/23 I 09/30 I 10/07 I 10/14 I 10/21 I 10/28 I 11/04 I 11/11 I11/18 I 1

2 EOG 18 unplanned unavailabili 7 days 100% Fri 05111118 Thu 05117118 100%

r- PD Clock ends 0 days 0% Fri 09114118 Fri 09114118 i 09/14/18

;r- PD identified (exited with TBD) 0 days 100% Fri 06129118 Fri 06129118 r+ 06/29/18 5 IRFB 2 hrs 100% Thu 07119118 Thu 07119118 100%

6 Planing SERP completed 2 hrs 0% Thu 07126118 Thu 07126118 0% I

---y- PD clock ends Odays 0% Sun 08112118 Sun 08112118 .. 8/12/18

ii- SOP clock begins Odays 0% Sun 08112118 Sun 08112118 9 Issue IR 0 days 0% Sun 08112118 Sun 08112118 08/12/18 10 Perform DRE & write repo~ 43 days 2% Wed 07118118 Wed 08129118 2%

n- SERP & DRE package 0 hrs 2% Wed 08129118 Wed 08129118 ~ 8/29/18 complete (ready for review)

;r Initial SERP with HQ 2 hrs 0% Thu 09/13118 Thu 09/13118 0%j 1 3 Write choice letter 13days 0% Thu 09113/18 Wed 09126118 0%

14 Send choice letter 1 hr 0% Wed 09126/18 Thu 09127118 0%1:ff 1 5 Reg conference 8 hrs 0% Sat 10/27118 Sun 10128/18 0'/,j 1 5 Write final determination letter 14days 0% Sun 10128118'sat11/10/18 17 Final letter issued 0 days 0% Sat 11110118 Sat 11110/18 ( ~ 1/10/18 1 8SOP clock ends - 0 days 0% Sat 11110118 Sat 11110118 ~ 1/10/1 8 Page 1

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Clinton Exelon Docket Number(s): EA Number: EA-08-104 50-461 (b)(5)

Issue Date: l{b)(S) Exh 1-1 0609.0STP

(b)(5)

Issue Date: ~ Exh1 -2 0609.0STP

(b)(5)

Issue Date: LJ Exh1-3 0609.05TP

(b )(5)

Issue Date: EJ Exh1 -4 0609.0STP

(b)(5)

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(b )(5)

Issue Date: l(b)(5) I Exh 1-6 0609.0STP

(b)(5)

Issue Date: LJ Exh1-7 0609.0STP

(b)(5)

Issue Date: EJ Exh 1-8 0609.0STP

(b)(5)

Issue Date: LJ Exh1-9 0609.0STP

(b )(5)

(b)(5) l Issue Date: .__ _.... Exh1-10 0609.0STP

(b)(5)

Issue Date: LJ Exh1-11 0609.0STP

(b)(5)

Issue Date: LJ Att1-1 0609.0STP

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Clinton Exelon Docket Number(s): EA Number: EA-Click here to enter text.

50-461 (b )(5)

Issue Date: l(b)(5) Exh1-1 0609.0STP

(b)(5)

Issue Date: LJ Exh1-2 0609.0STP

(b)(5)

Issue Date: ~ Exh1-3 0609.0STP

(b)(5)

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(b )(5)

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(b)(5)

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(b )(5)

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(b)(5)

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(b)(5)

Issue D a t e : ~ Exh1-10 0609.0STP

( b)(5)

Issue Date: EJ Exh1-11 0609.0STP

(b)(5)

Issue Date: ~ Exh1-12 0609.0STP

Issue Date: ~ Att1-1 0609.0STP From: Louden Patrick To: Murray Robert Cc: Lara Juno: stoedter Karla: Biemer Kenneth: Phillips Chacles: Draper Jason: Sanchez Santiago Elba: ~

~ ; Kozak Laura: Stone AnnMarie Subject : RE: Clinton SIT Discussion - Licensee Identified Date: Monday, July 02, 2018 3:07:1 1 PM Thanks for sharing this Rob.

Once Karla is back I would like to have a team discussion on this topic.

Pat From: M urray, Robert Sent: M onday, July 02, 2018 1:09 PM To: Louden, Patrick <Patrick.Louden@nrc.gov>

Cc: Lara, Julio <J ulio.Lara@nrc.gov>; Stoedter, Karla <Karla.Stoedter@nrc.gov>; Riemer, Kenneth

<Kennet h.Riemer@n rc.gov>; Phill ips, Cha rles <Char les.Phil li ps@nrc.gov>; Draper, Jason

<Jason.Draper@nrc.gov>; Sanchez Santiago, Elba <Elba.Sa nchezSantiago@nrc.gov>; Sargis, Daniel

<Daniel.Sa rgis@nrc.gov>; Kozak, Laura <Lau ra. Koza k@nrc.gov>; Stone, AnnMarie

<AnnMarie.Stone@nrc.gov>

Subject:

Clinton SIT Discussion - Licensee Identified Pat/ All-During the SIT exit last week, the licensee had asked about credit for some of the findings that we exited. I wanted to share some of my thoughts on the discussion as we are considering the licensee's feedback.

Consider the following definitions and discussion related to credit for identification.

Definitions from 0612:

03.05 Licensee-Identified. Licensee-identified findings and violations are (1) identified as a result of deliberate observation by licensee personnel; and (2) entered into the licensee corrective action program. Examples of deliberate observations that result in licensee-identified findings or violations include (1) those identified during activities such as post maintenance testing, operator rounds, engineering walkdowns, drills, critiques, or audits; and (2) degraded conditions identified during testing which do not result in test failure.

03.09 NRG-Identified. NRG-identified findings or violations are found by NRC inspectors, of which the licensee was not previously aware or had not been previously documented in the licensee's corrective action program. NRG-identified fi ndings or violations also include issues initially identified by the licensee to which the inspector has identified inadequacies in the licensee's characterization or evaluation of the issue of concern.

03.17 Self-Revealed. Self-revealed findings or violations are those identified as a result of a condition that (1) become apparent through a readily detectable degradation in material condition, capability, or functionality of equipment or plant operations; and (2) does not

meet the definition of licensee-identified or NRC-identified. Examples of self-revealed findings or violations include those revealed through: unplanned reactor trips and secondary plant transients; obvious equipment and piping failures; failed on demand testing ; valid plant or electronic dosimeter alarms; identification of large quantities of fluids in areas where one would not normally expect such a condition.

From IMC 0612, Appendix B Block 5 Is the finding licensee-identified? In determining whether a finding is licensee-identified, NRG-identified, or self-revealing, a measure of subjectivity is anticipated and accepted. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

(b )(5)

Sincerely, Rob

From: Kozak Laura To: "Joe Edom" Subject : RE: Clinton Training Material Date: Friday, July 20, 2018 8:09:00 AM Got it. Thank you.

From: Joe Edom hughes.com

Sent: Friday, July 20, 2018 7:45 AM To: Koza k, Laura <Laura.Kozak@ nrc.gov>

Subject:

[External_Sender) Clinton Train ing Materia l

Laura, This is the big file we discussed.

Non Responsive

....u..,

( Unton -UIE- 0..~Ql'll {IJ Tut&clay, .U, 24. 2011l5 :27£>1 PM

........11n, ......

Laura, so begin the questions.

Below is a sketch of the conlainment. It shows two airlocks. One at elevation 737 foot and the other at 828 fool . I know that we discussed air1ock and containment status du ring the SIT but I don'1remember Exelon's response. So ...

1. Are there any other airlocks besides those at 737 and 828?

2. What was the status of the primary containment airlocks during the entire time ol the unavailability of the Div, 2 EOG?

3. Where mere any other openings in c::ontainman1 that would prevent containmen1press1,1rizalion upon loss of SOC and subsoqvant steaming into primary oontainmen1 during the entire period of Div. 2 EOG unavailability?

4, E:icelon supplied a containment closure procedure. II penetrations were open, is there any reason why primary containment could not or would not be closed during any period of Div. 2 EOG unavailability?

5. Base HEP analysis assumes appropriate instrumentation is. available. 0 1most importance is RPV level. B-elow is a sketch of Ctinton*s. level ranges. The two ranges. that appear to be calibrated for the conditions ol in1erest are the stiuldown and luet zone instruments. What level instruments were available during the period of Div. 2 EOG unavailability?

By 1he way, I ran 1he Grand Gulf shuldown model with the HPCS pump, Div. 1 and 2 EDGs. failed during a late cold shutdown period. The CDF was - 3E*6 for a three day exposure period.

GG has three diesel fire pumps that are risk signilicanl d uring 1hls conflguralion. The lire water fault tree failure pr,obabllity was 4E*3. (99% from the HEP). The model has no credit fOf' FLEX or Otv. 3 to Div. I or 2 crosstle. Recovery times for EOGs and oHsite power are based on , 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Jell Mitman Non Responsive

~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)

(b)(5) 2 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn ~ R*s:0l 11.,,7 C""" "u*11~ n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

Note to requester: This page was provided in full in a previous release.

Cavity f ull End lower ing cavity level 09:43))begi1 13:54 ~ 6 inches below flange RCS water level lowering)) cavit RPV Last bolt level tensioned0l:51 C Mode 5 Mode4 2:24 Div. 2 EDG operable

Div. 2 EDG "available"Div. 2 SX availableRCIC restorable 21:040 inop.Div. 1 EDG (using Div. 1 DC Power) 02:30 unavailableDiv. 1 DC 01:30 HPCS DC 1/S & op End unavailableLPCS (Div. 1) recovera ble 08:00 (after fill & vent) HPCS hydroRHR/SDC A unavailableRHR / SDC A 5/9

I/S12:53 unavailable 00:30 5/16 Available 5/18 II

I 5/12 11:18 00:00 00:00 00:00 00:00

00 ~0 -- - ------*----*- e

* * *

I -

5/11 5/13 23: 28RHR/SDC B 7 5/15 5/17 r-J°'"

1/SRHR/SDC A OO~ 00:00 17:25Div. 2 AC Bus 1/S ro:OO 00 :00 00:00 eoq First)) bol tensionedQ

'°5730E~

I AT I/ ~ 23:09RHR/SDC B "Op erable"LPCI C & SRVs I 15:040Div. 2 available available

~-----------1.

Actual relative risk level --

Planned risk level (not to scale)

Version Date: 07-23-2018

- - - It 3

(b)(5) 4 ~ U.S.NRC l,,1n,*rd ~.,,,._, Nu("fn~ llfs:0l11,,,7 C""""lP'ft" ProttttiNf Pt.op.Jr 1111d 1/N Envfronmo,t

Ll"l L (')

..c

(b)(5) 6 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

(b)(5) 7 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

(b)(5) 8 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~ n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

(b)(5)

T 9 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

Ta.sl:Name D.latonI % SIM Frish Jtre l~~ _ AugJSi ~ ~ -Se~ember ___@_ctol:EI~ - - November - .i Compl~e r 05io6 05n3 I05120 Iosm ~ osno osnTTC6/2~8 oftITT onn fom9 08/05 oan2 IClln9 Iosns 09i02 09.09 I09nff03J13 09130 10.01 I10M I1oa1 Tons 11.04 I11n1 I11r.

2 I EOG 18unplanned unavailal 7days 100% Fri(l5111/18 Thu05/17/18 \o% i . . . . . . . ...................... ........... ......................................................... , ...... i... . . . . .

... ... .... . . ... ........... . ......... . ~9~~~ ..

3 I PO C lock ends 10daysl 0% Fri00/14118 Fri 09/14/18 I. .......... ... ......... ... . .. . ... ... .... .... ...... .........................'....

4 I PO idenlifled (exiled wilh TBl Odays 100% Friffi.129/18 Fri 06129/18 i 16/29118 5 I IRFB 2hrs 100% Thu 07/19/18 Thu 07/19/18 1003/4 I 6 Planin~ SERPcompleled 2hrs 0% Thu 07126/18 Thu 07m/181 0% I

.......................... ...... , ............ . ............... H*****"<I* ..... ............. '.' ,, .............. , .................. ,

7 PO clock ends 0days 0% Sun 00/12/18 Sun 08/12/18 8 SOP clock begins 0days 0% Sun 00/12/18 Sun 08/12/18 9 Issue IR 0days 0% Sun 00/12/18 Sun 08/12/18 10 I Perform DRE &wrrte report 43days 2% Wed 07/18/18Wed 08129/18

~ --~111111111111111111111111111111111111111111***

11 I SERP &DRE package 0hrs 2% Wed 00/29/18Wed 08129/18 1/2MI complele (ready forre-viev1) 0% Thu00/13/18 Thu09/11'18 i' ................ *............ T. . . . . . . . . . . . . . * *. . . . . . . *. .;. . . . . . *. . . . . . **. . . . . !' -.;;-*-*. . . . . . *. . . . . . . . *. . . . . . . *. . . . . . . . . . . . ,. . *. . . . . .

1il InitialSERPwrth HQ 2hrs 1~ Write choice letter 113days 0% Thu 00/13/18Wed 09ffi'18 I%

14 Send choice letter Hr 0% Wed 00/26/18 Thu 09127/18 0%

15 I Reg conference 8hrs 0% Sal 10/27/18 Sun 10fld/18 I'* * ****"""" . ............ . . L............,,,.,............. ' ............. ...............,,,' "'""""'. ,......... !. .. ,.,....... ,,,, .. ,........... ,.,

16 I Wri1efinal delerminalion lell 114days 0% Sun 10/28/18 Sal 11110/18 17 I Final letter issued Odays 0% Sat11/10/18 Sat 11 /10/18 18 I SOP clock ends 0days 0% Sal 11/10/18 Sal 11/10/18 Note to requester: This page was provided in full in previous releases. 10 U.S.NRC l,,1n,o*,d ~o rr-, Nu(:fn ~ R*s:0l 11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

From: Mitman Jeffrey To: Kozak Laura Subject : FW: Clinton SOP' Planning SERP Pre-Brief Presentation Date: Wednesday, July 25, 2018 11 :38:15 AM Attachments: Clinton lnop Both EDGs SD 072018 (3).optx, Importance: High Always helps if I add your name to the email.

This version incorporates Mike Montecalvo's edits.

Jeff Mitman From: M itman, Jeffrey Sent: Tuesday, July 24, 2018 3 :56 PM To: Monteca lvo, M ichael <M ichael.Monteca lvo @nrc.gov>

Subject:

Clinton SOP Planning SERP Pre-Brief Present at ion Mike, I've flushed out your start. Please take a look at the enclosed version. What is the current protocol for pre-briefing of planning SERPs, do we invite DIAS and OE?

Laura, we have scheduled a briefing with ORA management on the planning SERP.

Enclosed is the draft of what we put together. If you have a chance, comments are always appreciated.

Jeff Mitman From: Montecalvo, M ichael Sent: Tuesday, July 24, 2018 12:41 PM To: M itman, Jeffrey <Jeffrey Mjtman@nrc gov>

Subject:

presentation

Jeff, I am working on the presentation for tomorrow's prebrief. Attached is what I have so far (not much) and I will be working on it tonight after all my meetings for the day get complete. I am off on Thursday and Friday, so won't be at the planning SERP. I haven't had much time at all to look at this since picking up BC duties.

Mike

~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)

(b)(5) 2 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn ~ R*s:0l 11.,,7 C""" "u*11~ n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

Note to requester: This page was provided in full in previous releases.

Cavity full End lowering cavity level 09:43))begi1 13:54 ~ 6 inches below flange RCS water level lowering)) cavit RPV Last bolt level tensioned0l:51 C Mode 5 Mode4 2:24 Div. 2 EDG operable

Div. 2 EDG "available"Div. 2 SX availableRCIC restorable 21:040 inop.Div. 1 EDG (using Div. 1 DC Power) 02:30 unavailableDiv. 1 DC 01:30 HPCS DC 1/S & op End unavailableLPCS (Div. 1) recoverable 08:00 (after fill & vent) HPCS hydroRHR/SDC A unavailableRHR / SDC A 5/9

I/S12:53 unavailable 00:30 5/16 Available 5/18 II

I 5/12 11:18 00:00 00:00 00:00 00:00

00~0 -- - ------*----*- e

* * *

I -

5/11 5/13 23:28RHR/SDC B 7 5/15 5/17 r-J°'"

1/SRHR/SDC A OO~ 00:00 17:25Div. 2 AC Bus 1/S ro:OO 00:00 00:00 eoq First)) bol tensionedQ

'°5730E~

I AT I/~ 23:09RHR/SDC B "Operable"LPCI C & SRVs I 15:040Div. 2 available available

~-----------1.

Actual relative risk level --

Planned risk level (not to scale)

Version Date: 07-23-2018

- - - It 3

(b)(5) 4 ~ U.S.NRC l,,1n,*rd ~.,,,._, Nu("fn~ llfs:0l11,,,7 C""""lP'ft" ProttttiNf Pt.op.Jr 1111d 1/N Envfronmo,t

(b)(5) 5 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

(b)(5) 6 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

r--

00 en Ta.sl:Name D.latonI % SIM Frish Jtre l~~ _ AugJSi ~ ~ -Se~ember ___@_ctol:EI~ - - November - .i Compl~e r 05io6 05n3 I05120 Iosm ~ osno osnTTC6/2~8 oftITT onn fom9 08/05 oan2 IClln9 Iosns 09i02 09.09 I09nff03J13 09130 10.01 I10M I1oa1 Tons 11.04 I11n1 I11r.

2 I EOG 18unplanned unavailal 7days 100% Fri(l5111/18 Thu05/17/18 \o% i . . . . . . . ...................... ........... ......................................................... , ...... i... . . . . .

... ... .... . . ... ........... . ......... . ~9~~~ ..

3 I PO C lock ends 10daysl 0% Fri00/14118 Fri 09/14/18 I. .......... ... ......... ... . .. . ... ... .... .... ...... .........................'....

4 I PO idenlifled (exiled wilh TBl Odays 100% Friffi.129/18 Fri 06129/18 i 16/29118 5 I IRFB 2hrs 100% Thu 07/19/18 Thu 07/19/18 1003/4 I 6 Planin~ SERPcompleled 2hrs 0% Thu 07126/18 Thu 07m/181 0% I

.......................... ...... , ............ . ............... H*****"<I* ..... ............. '.' ,, .............. , .................. ,

7 PO clock ends 0days 0% Sun 00/12/18 Sun 08/12/18 8 SOP clock begins 0days 0% Sun 00/12/18 Sun 08/12/18 9 Issue IR 0days 0% Sun 00/12/18 Sun 08/12/18 10 I Perform DRE &wrrte report 43days 2% Wed 07/18/18Wed 08129/18

~ --~111111111111111111111111111111111111111111***

11 I SERP &DRE package 0hrs 2% Wed 00/29/18Wed 08129/18 1/2MI complele (ready forre-viev1) 0% Thu00/13/18 Thu09/11'18 i' ................ *............ T. . . . . . . . . . . . . . * *. . . . . . . *. .;. . . . . . *. . . . . . **. . . . . !' -.;;-*-*. . . . . . *. . . . . . . . *. . . . . . . *. . . . . . . . . . . . ,. . *. . . . . .

1il InitialSERPwrth HQ 2hrs 1~ Write choice letter 113days 0% Thu 00/13/18Wed 09ffi'18 I%

14 Send choice letter Hr 0% Wed 00/26/18 Thu 09127/18 0%

15 I Reg conference 8hrs 0% Sal 10/27/18 Sun 10fld/18 I'* * ****"""" . ............ . . L............,,,.,............. ' ............. ...............,,,' "'""""'. ,......... !. .. ,.,....... ,,,, .. ,........... ,.,

16 I Wri1efinal delerminalion lell 114 days 0% Sun 10/28/18 Sal 11110/18 17 I Final letter issued Odays 0% Sat11/10/18 Sat 11 /10/18 18 I SOP clock ends 0days 0% Sal 11/10/18 Sal 11/10/18 Note to requester: This page was provided in full in 10 U.S.NRC l,,1n,o*,d ~o rr-, Nu(:fn ~ R*s:0l 11.,,7 C""" "u*11~n previous releases. ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

Clinton Identification Credit Talking Points July 2017

Background:

The Clinton SIT team recently reviewed an issue where the Division 1 and Division 2 EDGs were discovered to be inoperable and unavailable concurrently during the May 2018 refueling outage. The EDG inoperability was found by an individual on operator rounds approximately 6.5 days after the condition occurred.

IMC 0612, Step 03.05 defines licensee-identified findings/violations as items that are identified as a result of deliberate observation by licensee personnel and are entered into the CAP. Examples of deliberate observations that result in licensee-identified issues include operator rounds.

IMC 0612, Step 03.17 defines self-revealed findings/violations as those identified as a result of a condition that become apparent through a readily ,detectable degradation in material condition, capability, or functionality of equipment or plant operations; and (2) does not meet the definition of licensee-identified or NRG-identified.

Examples include those revealed through: obvious equipment and piping failures; identification of large quantities of fluids in areas where one would not normally expect such a condition, etc.

5

Purpose:

1 ....(b-)(_ _) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____.

Basis Related Information:

.....I ___________________________(._b)........ (SJ

Block 5 of IMC 0612, Appendix B , states that a measure of subjectivity is anticipated and accepted when making decisions regarding identification credit. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send .

(b)(5'

From: Mitman Jeffrey To: Kozak Laura Cc: Montecalvo Michael

Subject:

RE: Clinton SDP Planning SERP Pre-Brief Presentation Date: Wednesday,July25, 20181:23:11 PM Attachments: Clinton loop Both EDGs SD 072018 f3\ pptx Laura, I've made you requested changes. The attached is what I'll use in the pre-briefing .

On a side note, if the re-exit occurs as expected, it wou ld be appreciated if some of the additional time gained could be set aside for the DRE. I know that the Region is squeezed by the constraints imposed by the process, but so is the DRE and this DRE requires building a model not simply pulling it off the self and exercising it Jeff Mitman From: Kozak, Laura Sent: Wednesday, July 25, 2018 12:48 PM To: Mitman, Jeffrey <Jeffrey.Mitman@nrc.gov>

Subject:

RE: Clinton SOP Planning SERP Pre-Brief Presentation Two comments -

On t he finding resolut ion schedule, the dat e the IR w il l be issued is going to cha nge because there is likely goi ng t o be a re-exit. Also, the dat es f urt her out w il l be set by the region and as you know are su bj ect to cha nge. Can you la bel t he schedule draft and make sure M ike and others know that t his w ill change but the most important point in front of us now is get t ing t he DRE done and conduct ing a SERP if necessary and exit ing and getti ng the report out ?

Thanks Laura From: M itman, Jeffrey Sent: Wednesday, July 25, 2018 11:38 AM To: Kozak, Laura <Laura,Kozak@nrc,goy>

Subject:

FW: Cli nt on SO P Pla nning SERP Pre-Brief Present ation Importance: High Always helps if I add your name to the email.

This version incorporates Mike Montecalvo's edits.

Jeff Mitman

~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)

(b)(5) 2 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn ~ R*s:0l 11.,,7 C""" "u*11~ n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

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Div . 2 EOG "available"Div. 2 SX availableRCIC restorable (using Div. 1 DC Power) 02:30 iydroLPCS / SR Alt. SDCRHR/SDC A O0S02:24 I Div. 2 EDG operable 21:040

Div. 2 EOG opNSPS opDiv. 2

Div. 1 4Kv bus 1/S but AC 1/S & opDiv. 2 inop.Div. 1 EDG 01:30 HPCS Div. 2 AC Bus 1/S 17:25 I DC 1/S & op 08:00 End hydroRHR/SDC A 1/S 12:53 unavailableDiv. 1 DC unavailableLPCS (Div. 1) unavailableRHR / SDC A recoverable I after fill & vent} HPCS unavailable 00:30 Avai lable 5/9 5/ 2 5/16 11:18 5/18 00:0C 5/1'- 00:00 00:00 00: )0 00:00 II

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Version Date: 07-23-2018 3

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... ... .... . . ... ........... . ......... . ~9~~~ ..

3 I PO C lock ends 10daysl 0% Fri00/14118 Fri 09/14/18 I. .......... ... ......... ... . .. . ... ... .... .... ...... ............. ............'....

4 I PO idenlifled (exiled wilh TBl Odays 100% Friffi.129/18 Fri 06FE/18 i 16/29118 5 I IRFB 2hrs 100% Thu 07/19/18 Thu 07/19/18 1003/4 I 6 Planin~ SERPcompleled 2hrs 0% Thu 07126/18 Thu 07m/181 0% I

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7 PO clock ends 0days 0% Sun 00/12/18 Sun 08/12/18 8 SOP clock begins 0days 0% Sun 00/12/18 Sun 08/12/18 9 Issue IR 0days 0% Sun 00/12/18 Sun 08/12/18 10 I Perform DRE &wrrte report 43days 2% Wed 07/18/18Wed 08FE/18

~ --~111111111111111111111111111111111111111111***

11 I SERP &DRE package 0hrs 2% Wed 00/29/18Wed 08FE/18 1/2MI complele (ready forre'viev1) 0% Thu00/13/18 Thu09/11'18 i' ................ *............ T. . . . . . . . . . . . . . * *. . . . . . . *. .;. . . . . . *. . . . . . **. . . . . !' -.;;-*-*. . . . . . *. . . . . . . . *. . . . . . . *. . . . . . . . . . . . ,. . *. . . . . .

1il InitialSERPwrth HQ 2hrs 1~ Write choice letter 113days 0% Thu 00/13/18Wed 09ffi'18 I%

14 Send choice letter 1hr 0% Wed 00/26/18 Thu 09127/18 0%

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16 I Wri1efinal delerminalion lell 114 days 0% Sun 10/28/18 Sal 11110/18 17 I final letter issued Odays 0% Sat11/10/18 Sat 11 /10/18 18 I SOP clock ends 0days 0% Sal 11/10/18 Sal 11/10/18 10 U.S.NRC l,,1n,o*,d ~o rr-, Nu(:fn ~ R*s:0l 11.,,7 C""""u*11~ n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t

From: Stoedter Karla To : Sanchez Santiago Elba : Sargis pan jel: Louden Patrick Subject : Identification Credit Talking Points for Clinton - Revised Date: Thu rsday, July 26 , 2018 1 :43 :00 PM Attachments: k!filltillcation Credit Talking P_oint0QQ3Ll!ocx See attached and let me know if you have comments or questions.

Clinton Identification Credit Talking Points July 2017

Background:

The Clinton SIT team recently reviewed an issue where the Division 1 and Division 2 EDGs were discovered to be inoperable and unavailable concurrently during the May 2018 refueling outage. The EDG inoperability was found by an individual on operator rounds approximately 6.5 days after the condition occurred.

IMC 0612, Step 03.05 defines licensee-identified findings/violations as items that are identified as a result of deliberate observation by licensee personnel and are entered into the CAP. Examples of deliberate observations that result in licensee-identified issues include operator rounds.

IMC 0612, Step 03.17 defines self-revealed findings/violations as those identified as a result of a condition that become apparent through a readily ,detectable degradation in material condition, capability, or functionality of equipment or plant operations; and (2) does not meet the definition of licensee-identified or NRG-identified.

Examples include those revealed through: obvious equipment and piping failures; identification of large quantities of fluids in areas where one would not normally expect such a condition, etc.

5

Purpose:

...r b_)_( _) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __,

Basis Related Information:

. . _ _ _ I_ _ _ _ _ _ _ _ _ b)j

_(. . . . . . . . . . . . . . .

Block 5 of IMC 0612, Appendix 18, states that a measure of subjectivity is anticipated and accepted when making decisions regarding identification credit. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

(b)(5)

(b)(5)

From : Kozak Laura To : Thompson John: Sigmon Rebecca : Robles-Alcaraz Jesse Subject : IFRB Date: Thursday, July 26 , 2018 9:20 :00 AM Attachments: Clinton EOG Unavailability planning SERP worksheet.docrn Copy of IFRB Status July 13 201 s open and closed.xlsx Palisades 1-1 DG Turbocharger Jacket Water Leak - loitial !EBB docm Attached is my spreadsheet, updated as of July 18 of all items that have been to an IFRB.

I attached two examples of IFRB forms - a Clinton example and the Palisades example we discussed.

Let me know if you have any additional questions.

Laura

Inspection Finding Review Board - Issues Under Development Discovery IFRB Date Issue IFRB Conclusion Open/Closed/Status Date Chair Non Responsive (b )(5)

Non Responsive (b )(5)

Non Responsive

-~

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C 0

a.

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Q) a::

C 0

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EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Palisades Entergy Docket Number(s): EA Number: EA-18-XXX 50-255 (b)(5)

Issue Date: l(b)(S)

I Exh1 -1 0609.0STP

(b)(5)

Issue Date: LJ Exh1-2 0609.05TP

(b)(5)

Issue Date: ~ Exh1 -3 0609.0STP

(b )(5)

Issue Date: EJ Exh1 -4 0609.0STP

(b )(5)

Issue Date: ~ Exh1 -5 0609.0STP

(b)(5)

Issue Date: .__ _I l(b)(S)

___. Exh1 -6 0609.0STP

(b)(5)

Issue Date: EJ Exh1-7 0609.05TP

(b )(5)

Issue Date: LJ Exh1 -8 0609.0STP

(b)(5)

Issue Date: ....

l(b- )(-5)_ _, Exh1-9 0609.05TP

(b)(5)

Issue Date: ~ Exh1-10 0609.0STP

(b)(5)

Issue Date: l(b)(5) Exh1-11 0609.0STP

(b)(5)

Issue Date: ~ Exh1-12 0609.05TP

(b)(5)

Issue Date: LJ Att1-1 0609.0STP

EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:

Clinton Exelon Docket Number(s): EA Number: EA-08-104 50-461 (b)(5)

Issue Date: !'-'-

( b-'-

)('5'-

-) _ _. Exh1-1 0609.0STP

(b)(5)

Issue Date: .....

l(b_)(S_) ___ Exh1 -2 0609.0STP

(b)(5)

Issue Date: ~ Exh1-3 0609.05TP

(b)(5)

Issue Date: ~ Exh1-4 0609.0STP

(b)(5)

Issue Date: l(b)(S) I Exh1 -5 0609.0STP

(b)(5)

Issue Date: l(b)(5) I Exh1 -6 0609.0STP

(b)(5)

Issue Date: EJ Exh1-7 0609.0STP

(b)(5) 5 Issue Date: l(b)( ) I Exh 1-8 0609.0STP

(b)(5)

Issue Date: l(b)(S) Exh1-9 0609.0STP

(b)(S)

(b)(5)

Issue Date:

l I Exh1-10 0609.0STP

(b )(5)

Issue Date: ....

l(b-)(-5)_ ..... Exh1-11 0609.0STP

(b )(5)

Issue Date: ~ Att1-1 0609.0STP

From: Kozak Laura To : Mitman Jeffrey Cc: Montecalvo Michael

Subject:

RE: RClint on SDP Planning SERP Pre-Brief Results Date: Thursday, July 26, 2018 7:14:00 AM Thanks for the update.

(b)(5)

I think Mike has a point that we should consider. I want to read up on the discussion of work processes in the SPAR-H NUREG to see how well it fits.

Laura From: Mitman, Jeffrey Sent: Wednesday, July 25, 2018 2:59 PM To: Koza k, Laura <Laura.Kozak@ nrc.gov>

Cc: Monteca lvo, Michael <Michael.Monteca lvo@nrc.gov>

Subject:

RClinton SDP Plann ing SERP Pre-Brief Res ults Laura, the pre-brief for tomorrow's planning SERP went well. While it was an inquisitive discussion there was no reluctance to move forward with the issue or to have HQ perform the DRE. Nothing points to anything other than a proforma discussion at the planning SERP.

(b)(5)

Jeff Mitman

From: Stoedter Karla To : Phillips Charles Subject : FW: Identification Credit Talking Points (003) .docx Date: Monday, July 30 , 2018 8:39:00 AM Attachments: k!filltillcation Credit Talking P_oint0QQ3Ll!ocx See attached.

From: Sanchez Santiago, Elba Sent: Friday, Ju ly 27, 2018 6:48 AM To: Stoedter, Karla <Karla.Stoedter@nrc.gov>

Subject:

Identification Cred it Tal king Poin ts (003).docx

Karla, Attached are my comments on the talking points.

Thanks, Elba

Clinton Identification Credit Talking Points July 2017

Background:

The Clinton SIT team recently reviewed an issue where the Division 1 and D ivision 2 EDGs were discovered to be inoperable and unavailable concurrently during the May 2018 refueling outage. The EOG inoperability was found by an individual on operator rounds approximately 6.5 days after the condition occurred.

IMC 0612, Step 03.05 defines licensee-identified find ings/violations as items that are identified as a result of deliberate observation by licensee personnel and are entered into the CAP. Examples of deliberate observations that result in licensee-identified issues include operator rounds.

IMC 0612, Step 03.17 defines self-revealed findings/violations as those identified as a result of a cond ition that become apparent through a readily detectable degradation in material condition, capability, or functionality of equipment o r plant operations; and (2) does not meet the definition of licensee-identified or NRG-identified.

Examples include those revealed through: obvious equipment and piping failures; identification of large quantities of fluids in areas where one would not normally expect such a cond ition, etc.

Purpose:

_l(_

b)_(5_)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Basis Related Information:

(b)(5)

Block 5 of IMC 0612, Appendix B, states that a measure of subjectivity is anticipated and accepted when making decisions regarding identification credit. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

(b )(5)

(b )(5)

From: Kozak Laura To: Mitman Jeffrey Cc: Montecalvo Michael Subject : RE: Clinton SDP Planning SERP Pre-Brief Results Date: Monday, July 30, 2018 9 :07:00 AM I reviewed the Work Processes PSF - both the NUREG and the Step by Step Instructions.

I think we should consider applying this PSF to HFEs that are quantified. The finding we (b)(5)

Thoughts?

From: Mitman, Jeffrey Sent: Thursday, July 26, 2018 12:22 PM To: Kozak, Laura <Laura.Kozak@ nrc.gov>

Cc: Montecalvo, Michael <Michael.Montecalvo@nrc.gov>

Subject:

RE: RClinton SO P Pla nning SERP Pre-Brief Results (b)(5) ********** J - - -*-** **-*...-iiiiiii --= *** =

- -*=*-*=*-****;;;;;; ;;;;;;;;;;;;;;::::;::=====:::....- - - - - - - - - - - _ j (b)(5) .__.....___, ******-******-*******-****-*****-* ***-*****- - - - - - - ' We can quantify, therefore we should just take the time to quantify.

As to Mike's point: Don't forget the insights in SPAR-H Step by Step. The discussion on work processes starts on Page 12. A copy is attached.

Jeff Mitman From: Kozak, Laura Se nt: Thursday, July 26, 2018 8:15 AM To: Mitman, Jeffrey <Jeffrey Mjtman@nrc gov>

Cc: Monteca lvo, Michael <Michael Montecalyo@nrc gov>

Subject:

RE: RClinton SO P Planning SERP Pre-Brief Results Thanks for the update.

I think Mike has a point that we should consider. I want to read up on the discussion of work processes in the SPAR-H NUREG to see how well it fits.

Laura From: Mitman, Jeffrey Sent: Wednesday, July 25, 2018 2:59 PM To: Kozak, La ura <Laura Kozak@nrc gov>

Cc: Monteca lvo, M ichael <Michael Monteca lvo@nrc gov>

Subject:

RClinton SOP Planning SERP Pre-Brief Results Laura, the pre-brief for tomorrow's planning SERP went well. While it was an inquisitive discussion there was no reluctance to move forward with the issue or to have HQ perform the DRE. Nothing points to anything other than a proforma discussion at the planning SERP.

(b )(5)

Jeff Mitman

From : Stoedter Karla To : Phillips Charles Subject : CLl2018050 SIT draft Rev 1 comments Date: Tuesday, July 31 , 2018 9 :20:00 AM Attachments: CLl2018050 SIT draft Rev 1 kks.docx.

See attached. It looks worse than it really is. The fi le is also on the G drive in the Branch 1/draft reports folder.

K

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 2443 WARRENVILLE RO. SUITE 210 LISLE, ILLINOIS 60532-4352 EA- 18-104 Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION - NRC SPECIAL INSPECTION REPORT 05000461/2018050 (b)(5)

(b)(5) 2 Enclosure [#)

(b)(5)

(b )(5)

(b)(5)

(b )(5)

(b)(5)

(b )(5)

(b)(5)

(b )(5)

(b)(5)

(b )(5)

(b)(5)

(b )(5)

(b)(5)

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 2443 WARRENVILLE ROAD, SUITE 210 LISLE, ILLINOIS 60532-4352 MEMORANDUM TO: Charles Phillips, Project Engineer Division of Reactor Projects, Branch 1 FROM: Patrick L. Louden, Director IRA/

Division of Reactor Projects

SUBJECT:

SPECIAL INSPECTION TEAM CHARTER FOR INOPERABILITY OF THE CLINTON POWER STATION DIVISION 1 AND DIVISION 2 EMERGENCY DIESEL GENERATORS (b)(5)

(b)(5)

{b){5)

(b)(5)

Note to requester: The attached .docx file were processed in the final release . The document is not a ain included here.

From: Phillips Charles To : Skokowski Richard : Kozak Laura Cc : Stoedter Karla Subject : Clin ton SIT report draft Date: Tuesday, July 31 , 2018 3:16:57 PM Attachments: CLl 2018050 SIT draft Rev 1 kks.docx imaaeoo1 ° a Rick and Laura, Karla wanted you two to have a chance to review th is before we sent it to final.

~'Pledtiµ PE Branch 1, DRP 630-829-9572 Charles. Phillips@N RC.GOV

From : Kozak Laura To : Mitman Jeffrey Subject : FW : Re-exit Notes for Clinto n today Date: Friday, August 03 , 2018 10:37:00 AM Attachments: llilcl!illfill~.

Jeff Just FYI - Chuck conducted the re-exit meeting today and here are his notes.

Laura From: Phill ips, Charles Sent: Friday, August 03, 2018 9 :10 AM To: Sargis, Daniel <Daniel. Sargis@n rc.gov>; Sanchez Santiago, Elba

<El ba.Sa nchezSa nt iago@nrc.gov>; M urray, Robert <Robert.Murray@ nrc.gov>; Draper, Jason

<Jason .Draper@ nrc.gov>; Stoedter, Karla <Karla .Stoedter@nrc.gov>; Kozak, La ura

Subject:

Re-exit Notes for Clinto n today

Clinton SIT Re-exit Meeting Notes August 3, 2018 833-723-8900 (b)(6) J. - I This is the re-exit for IR 2018-050 Who's on the Phone?

I plan on only discussing changes to what I exited on June 29th .

Section 4 of the Report which discusses the probable causes of the event and contains the PD that is potentially greater than Green the report will be issued as TBD. And the Licensee identification credit for this violation will not be given:

IMC 0612, Step 03.05 defines licensee-identified findings/violations as items that are identified as a result of deliberate observation by licensee personnel and are entered into the CAP. Examples of deliberate observations that result in licensee-identified issues include operator rounds.

IMC 0612, Step 03. 17 defines self-revealed findings/violations as those identified as a result of a condition that become apparent through a readily detectable degradation in material condition, capability, or functiona lity of equipment or plant operations; and (2) does not meet the definition of licensee-identified or NRG-identified. Examples include those revealed through: obvious equipment and piping failures; identification of large quantities of fluids in areas where one would not normally expect such a condition, etc.

Block 5 of IMC 0612, Appendix B, states that a measure of subjectivity is anticipated and accepted when making decisions regarding identification credit. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory messag-e that the determination could send.

(b)(5)

(b)(5' In addition we made the following comment in Section 5. The inspectors did not conclude that training deficiencies for equipment operators contributed to this event; however, the inspectors were concerned that equipment operators' standards for thorough tours, attention to detail in the plant, perceived time pressure, and understanding of plant status were contributors to the event.

In Section 8 of the report, which reviewed operating experience, we previously stated that there would be a violation of the license for having the 1CO609 valve in the wrong position for several months. We've changed our position and are calling this a finding. We are giving you identification credit for this finding . In this case the valve position was not easily identifiable.

The valve is high in the air, the valve position cannot be discerned from the ground level and the identification of the locked status of the valve is difficult. We feel the identification of the valve in the unlocked position in this case required good observation skills and a questioning attitude.

We normally don't document licensee identified findings but because of the nature of the charter we have to.

In addition we made an addition to my exit comments about the corrective actions associated with this issue. Your corrective actions were to put the valve into its correct position and to require each operator to read a daily order, which was effective from September 30 through October 3, 2016, that discussed the requirements for tracking the status of plant equipment.

The daily order stated that equipment status could be tracked in one of five approved methods.

One of those methods, an example given by the licensee, was an open procedure and that the open procedure must be documented in the control room log. This was essentially what the SRO told the inspectors happened in the case of the Division 2 EOG air receiver isolation valves. The SRO stated he was required to log the out-of-service activity in the control room logs and he believed that CPS 3506.01P002 was the procedure in progress to control equipment status. The inspectors concluded the licensee's response to the internal operating

experience was ineffective and may have actually reinforced the behavior of tracking equipment status using the control room logs.

From: Kozak Laura To: Mitman Jeffrey Subject : RE: RE: Questions Date: Friday, August 03, 2018 4:51 :00 PM

{b)(5)

From: Mitman, Jeffrey Se nt: Friday, August 03, 2018 4:43 PM To: Koza k, Laura <Laura.Kozak@nrc.gov>

Subject:

RE: RE: Quest ions Would you let me know how this affects clocks and due dates. I'd like to update my Gantt chart. Thanks.

Jeff Mitman From: Kozak, Laura Sent: Thursday, August 02, 2018 1:38 PM To: Mitma n, Jeffrey <Jeffrey Mjtman@nrc gov>

Subject:

RE: RE : Questions Forgot to mention - Chuck planning to re-exit tomorrow with Clinton. The re-exit is because the two green findings were slightly changed. The finding we are dealing with has not changed .

The report is in draft and will likely be issued in the next couple of weeks (my guess). It describes the significance of the issue we are working on from the phase 1 and 2 perspective and calls it TBD because a phase 3 or DRE is ongoing.

Laura From: Mitman, Jeffrey Sent: Thursday, August 02, 2018 10:33 AM To: Koza k, Laura <Laura.Kozak@nrc.gov>

Subject:

RE : RE: Questions Laura, do you know what Exelon is using Gothic to calculate? I assume it is the TTB and TTCU analysis or it could be some containment calcs.

Thanks.

Jeff Mitman From: Kozak, Laura Sent: Thursday, August 02, 2018 11:24 AM To: Mit ma n, Jeffrey <Jeffrey.Mitman@nrc.gov>

Cc: Montecalvo, Michael <Michael.Montecalvo@nrc.gov>

Subject:

FW: RE: Questions From: Edom, Joseph T:(Contractor - GenCo-Nuc) [mailto*Joe Edom@exeloncorp.com]

Sent: Thursday, August 02, 2018 10:20 AM To: Kozak, Laura <Laura Kozak@nrc gov>

Cc: Joe Edom - Jensen Hughes (J Edom@jensenhughes com) <JEdom@jensenhughes com>

Subject:

[External_Sender) RE: Questions Hi Laura.

Just wanted to update you on the status of the question responses. We are working to get the majority of them to you by the end of the week. I requested the site prepare a written response that we could send you and then set up a call to discuss them. My guess is that question 6 on the reliability wi ll take a little bit longer,.

probably into next week.

We are also looking to have the GOTHI C analysis signed off by Friday or Monday and the risk assessment that we prepared will follow that sign off.

Does t hat still meet your needs?

Thank you.

Joe Edom I Senior Corporate Risk Management Engineer JENSEN HUGHES Advancing the Science of Safety One Trans Am Plaza Drive I Suite 200 I Oakbrook Terrace, IL 60181 (b)(6) 0: +1 630~627-2277j.G: j ** jl F: + 1 630-627-2278 JEdom@jensenhughes com I www jensenhughes com

++++++++++++++++++++++++++++++++++++++++++++++++

Exelon E-mail : joe .edom@exeloncorp.com

From: Kozak, Laura [1]

Sent: Thursday, July 26, 2018 2:37 PM To: Edom, Joseph T:(Contractor - GenCo-Nuc) <Joe.Edom@exeloncorp.com>

Subject:

[EXTERNAL) Questions Joe - Here are the questions that I mentioned yesterday. Please give me a call at your convenience to discuss.

Laura

1. Are there any other airlocks besides those at 737 and 828?

2. What was the status of the primary containment airlocks during the entire ti me of the unavailability of the Div. 2 EDG?

3. Where there any other openings in containment that would prevent containment pressurization upon loss of SDC and subsequent steaming into primary containment during the entire period of Div. 2 EDG unavailability?

4. Exelon supplied a containment closure procedure. If penetrations were open, is there any reason why primary containment could not or would not be closed during any period of Div. 2 EDG unavailability?

5. Base HEP analysis assumes appropriate instrumentation is available. Of most importance is RPV level. The two ranges that appear to be calibrated for the conditions of interest are the shutdown and fuel zone instruments. What level instruments were available during the period of Div. 2 EDG unavailability?

6. Please provide reliability data for FLEX equipment (number of starts, duration of runs, and number of failures to start or run). Please provide failure probabilities derived from the previous data. For equipment failures, please provide the associated condition report.

7. For the simulator exercise related to FLEX, was the Division 3 DG available? The guide indicates the HPCS pump shaft was damaged but is silent on the availability of the DG.

8. Training material for the Division 3 cross-tie includes a 5 minute discussion of the procedure during an EDMG-based simulator exercise and a DBIG training session covering all EDMGs with 2 slides showing the cross-tie procedure and a diagram of the electrical line-up. Does training include required walk-throughs of the procedure in the field?

This Email message and any attachment may contain information that is proprietary, legally privileged, confidential and/or subject to copyright belonging to Exelon Corporation o r its affiliates ("Exelon"). This E mail is intended sole ly for the use of the person(s) to whic h it is addressed. If you are not an intended recipient, or the employee or agent responsible for

delivery of this Email to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this Email is strictly prohibited. If you have received this message in error, please immediately notify the sender and permanently delete this Email and any copies. Exelon policies expressly prohibit employees from making defamatory or offensive statements and infringing any copyright or any other legal right by Email communication. Exelon will not accept any liability in respect of such communications. -

EXCIP

From: Stoedter Karla To : Kozak Laura Subject : talki ng points for self revealing vs. licensee identified Date: Friday, August 03 , 2018 8:56 :49 AM Attachments: k!filltillcation Credit Talking P_oint0QQ3Ll!ocx Here you go.

Clinton Identification Credit Talking Points July 2017

Background:

The Clinton SIT team recently reviewed an issue where the Division 1 and Division 2 EDGs were discovered to be inoperable and unavailable concurrently during the May 2018 refueling outage. The EDG inoperability was found by an individual on operator rounds approximately 6.5 days after the condition occurred.

IMC 0612, Step 03.05 defines licensee-identified findings/violations as items that are identified as a result of deliberate observation by licensee personnel and are entered into the CAP. Examples of deliberate observations that result in licensee-identified issues include operator rounds.

IMC 0612, Step 03.17 defines self-revealed findings/violations as those identified as a result of a condition that become apparent through a readily ,detectable degradation in material condition, capability, or functionality of equipment or plant operations; and (2) does not meet the definition of licensee-identified or NRG-identified.

Examples include those revealed through: obvious equipment and piping failures; identification of large quantities of fluids in areas where one would not normally expect such a condition, etc.

Purpose:

(b)(S)

Basis Related Information:

. _ I_ _ _ _ _ _ _ _ _ _ (b)J

Block 5 of IMC 0612, Appendix 18, states that a measure of subjectivity is anticipated and accepted when making decisions regarding identification credit. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

(b)(5)

(b)(5)

From : Stoedter Karla To : west Steven Subject : FW: talking points for Clinton SIT finding Date: Wednesday, August 08 , 2018 9:28:00 AM Attachments: k!filltillcation Credit Talking P_ointsJQQ3Ll!ocx

Steve, Here are the talking points on the Clinton identification credit issue we discussed this morning . Let me know if you have additional questions.

Karla From: Rutkowski, Joh n Sent: Wednesday, Au gust 08, 2018 8:02 AM To: Stoedter, Karla <Karla.Stoedter@nrc .gov>

Cc: Cameron, Jamnes <Jamnes.Cameron@nrc.gov>

Subject:

FW: ta lking points for Clint on SIT fi nding Thanks Karla.

JER From: Stoedter, Kar la Sent: Wednesday, August 08, 2018 7:42 AM To: Rutkowski, John <John Rutkowskj@nrc ~ov>

Subject:

ta lking points for Clinton SIT find ing

Jack, Karla

Clinton Identification Credit Talking Points July 2017

Background:

The Clinton SIT team recently reviewed an issue where the Division 1 and Division 2 EDGs were discovered to be inoperable and unavailable concurrently during the May 2018 refueling outage. The EDG inoperability was found by an individual on operator rounds approximately 6.5 days after the condition occurred.

IMC 0612, Step 03.05 defines licensee-identified findings/violations as items that are identified as a result of deliberate observation by licensee personnel and are entered into the CAP. Examples of deliberate observations that result in licensee-identified issues include operator rounds.

IMC 0612, Step 03.17 defines self-revealed findings/violations as those identified as a result of a condition that become apparent through a readily ,detectable degradation in material condition, capability, or functionality of equipment or plant operations; and (2) does not meet the definition of licensee-identified or NRG-identified.

Examples include those revealed through: obvious equipment and piping failures; identification of large quantities of fluids in areas where one would not normally expect such a condition, etc.

Purpose:

r .__)(_S_

) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____.

Basis Related Information:

.l.____________

__.(b.........,

Block 5 of IMC 0612, Appendix 18, states that a measure of subjectivity is anticipated and accepted when

)J making decisions regarding identification credit. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

(b )(5)

(b)(5)

Note to requester: Attachment is a non-responsive record due to clarifying the request to exclude licensee originated documents.

From: Kozak Laura To: Mitman Jeffrey: Montecalvo Michael Subject : FW: Responses to Questions 1-5, 7 and 8 Date: Thursday, August 09, 2018 1:22:00 PM Attachments: SRA Plan Response to NRC Questions 18-9-18).odf I will post these on sharepoint From: Edom, Joseph T:(Contractor - GenCo- Nuc) [ma ilto:Joe.Edom@exeloncorp.com]

Sent: Thursday, August 09, 2018 1:16 PM To: Koza k, Laura <Laura.Kozak@ nrc.gov>

Subject:

[External_Sender] Responses to Questions 1-5, 7 and 8 Laura, Attached are the responses t o the questions you asked . I am going through them t o gather the procedures and other mat erial ref erenced in the responses and will be sending those today as well.

Joe Edom I Senior Corporate Risk Management Engineer JENSEN HUGHES Advancing the Science of Safety One Trans Am Plaza Drive I Suite 200 I Oakbrook Terrace, IL 60181 (b)(6) . . . . .o:+1630-627-2477J Gl . !IF: +1 630-627-2278 JEdom@ieosenhughes com I www jensenhughes com

++++++++++++++++++++++++++++++++++++++++++++++++

Exelon E-mail: joe edom@exeloncorp com This Email message and any attachment may contain information that is proprietary, legally privileged , confidential and/or subject to copyright belonging to Exelon Corporation or its affiliates ("Exelon"). This Email is intended solely for the use of the person(s) to whic h it is addressed. If you are not an intended recipient, or the employee or agent responsible for delivery of this Email to the intended recipient(s), you are hereby notified that any dissemination, distribution o r copying of this Email is strictly prohibited. If you have received this message in error, please immediately notify the sender and permanently delete this Email and any copies. Exelo n policies expressly prohibit employees from making defamatory or offensive statements and infring ing any copyright or any other legal right by Email communication. Exelon will not accept any liability in respect of such communications. -

EXCIP

From: Helton Donald To: Kozak Laura: Garmoe Alex: Mitman Jeffrey

Subject:

ROP metrics w.r. t. Clinton SDP Date: Thursday, August 09, 2018 12:41 :40 PM Laura / Alex / Jeff:

(b)(5)

Don THESE ARE UNOFFICIAL VALUES As of IFRB As of Current Notes on 7/19 Planning SERP Inspection- Event/Condition 5/17/2018 related Report Date dates Date Reactive ~5/24/ 18 Have not Inspection Need confirmed the Determined actual d ate with the Reg ion SIT Entrance 6/20/2018 Meeting SIT Inspection 6/29/2018 Exit Meeting Re-exit TBD TBD 8/3/2018 SIT Inspection TBD TBD TBD, but e.g.,

Report Issued 8/ 15/2018 ROP and Reactive Met by 6/20/18 entrance due to lag between 30 days from Traditional Inspection discovery of condition on 5/17/18 and when the the Enforcement Initiation metric Region determined that a reactive inspection determination a Metrics [E-2] was required reactive inspection is required ROP inspection 9/14/2018 120 days from timeliness metric issue

[E-4] identification date ROP report issue 10/31/2018 (est. assuming 9/17/2018 45 days from metric [0-1] full E-4 time is used) final exit on the PD Enforcement 10/27/2018 12/1/2018 120 days from

action metric final exist on the PD ROP SOP metric 1/29/2019 (est. assuming TBD, but 90 days from

[E-5] full E-4 and 0 -1 time is e.g.,11 / 13/2018 inspection used) report issuance 255-day overall 1/29/2019 255 days from target to the discovery of complete all the activity evenUcondition SOP-related Initial 8/29/2018 8/29/2018 8/29/2018 Milestones DRE/SERP Package Ready for Review Initial SERP - 9/ 13/2018 9/13/2018 target Choice letter - 9/26/2018 9/26/2018 issued Regulatory - 10/27/2018 10/27/20 18 Conference Final - 11 /10/2018 11/10/2018 Determination Letter Issued Don Helton Division of Inspection and Regional Support (Rotational)

Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission (301 ) 415-1545

From: Mitman Jeffrey To: Kozak Laura: Phillips Charles Subject : RE: My thoughts on the Clinton licensee analysis.

Date: Friday, August 10, 2018 4:39:23 PM (b )(5)

Jeff Mitman From: Kozak, Laura Sent: Friday, August 10, 2018 2:37 PM To: Phillips, Charles <Charles.Phillips@ nrc.gov>

Cc: Mitman, Jeffrey <Jeffrey.Mitman@nrc.gov>

Subject:

RE: My t houghts on the Clinton licensee analysis.

Thanks Chuck. I appreciate you looking at the analysis.

Laura From: Phillips, Charles Sent: Friday, August 10, 2018 1:23 PM To: Kozak, Laura <Laura Kozak@nrc.gov>

Subject:

My thoughts on the Clint on licensee ana lysis.

(b )(5)

Non Responsive (b )(5)

(b)(5)

(b )(5)

(b)(5)

From: Orlikowski Robert To: Kozak Laura: Giessner John: Cameron Jamnes: Lara Julio: Hanna John: Lambert Kenneth Cc: Roberts Parcell

Subject:

RE: Action - today- Final White Clinton Date: Friday, March 29, 2019 8:04:04 AM (b )(5)

Bob From: Kozak, Laura Sent: Friday, March 29, 2019 7:26 AM To: Giessner, John <John.Giessner@nrc.gov>; Cameron, Jam nes <Jamnes.Cameron @nrc.gov>; Lara, Ju lio <J ulio. Lara@nrc.gov>; Orlikowski, Robe rt <Robert.Orlikowski@nrc.gov>; Ha nna, John

<John. Hanna@ nrc.gov>; Lambert, Kenneth <Kenneth. Lambe rt@nrc.gov>

Cc: Roberts, Darrel l <Darrell.Roberts@n rc.gov>

Subject:

RE: Action - today- Final Whit e Clinton From: Giessner, John Sent: Friday, March 29, 2019 6:49 AM To: Cameron, Jamnes <Jamnes Cameron@nrc,gov>; Lara, Ju lio <Ju lio,Lara@nrc,gov>; Orlikowski, Robert <Robert Orlikowski@orc gov>; Hanna, John <John Hanna@nrc gov>; Kozak, La ura

<Laura Kozak@nrc gov>; Lambert, Kenneth <Kenneth Lambert@nrc gov>

Cc: Roberts, Darrell <DarreU.Roberts@nrc.gov>

Subject:

Action - today- Final Wh ite Clinton All, Darrell reviewed and signed the letter, I also looked at it. We were very pleased with the level of detail and thoroughness of the evaluation! A couple items to highlight and then one possible change. Please get back to me by noon (b)(5)

Action is in highlight.

Jack

From : Kozak Laura To : Mitman Jeffrey Subject : RE : Clinton FLEX Suppression Pool Cooling Date: Monday, August 13, 2018 9:26:00 AM It looks like the valve is opened in step 4.2.4 Yes, I confirm that the panels are indeed load shed and the steps in 4.1.12 will have no impact. Unless, they back out of load shedding. If they back out of load shedding (just go turn the power back on), and they have not adjusted the containment spray initiation logic, it looks like there would be an impact to FLEX suppression pool cooling.

From: Mitman, Jeffrey Sent: Friday, August 10, 2018 5:01 PM To: Kozak, Laura <Laura.Kozak@nrc.gov>

Subject:

Clin ton FLEX Suppression Pool Cool ing (b )(5)

Thanks.

Jeff Mitman

From: Stoedter Kaela To: West Steven Subject : RE: talking points for Clinton SIT finding Date: Monday, August 13, 2018 5:53:00 AM Steve (b)(5)

Thanks, Karla From: West, Steven Sent: Friday, August 10, 2018 12:16 PM To: Stoedter, Ka rla <Karla.Stoedt er @nrc.gov>

Subject:

RE : t alking points for Cl inton SIT finding

Karla, (b)(5)

Steve From: Stoedter, Karla Sent: Wednesday, August 08, 2018 9:29 AM To: West, Steven <Steven.West@nrc.gov>

Subject:

FW: talking points for Clint on SIT finding

Steve, Here are the talking points on the Clinton identification credit issue we discussed this morning. Let me know if you have additional questions.

Karla From: Rutkowski, John Sent: Wednesday, August 08, 2018 8:02 AM To: Stoedter, Karla <Karla Stoedter@nrc gov>

Cc: Cameron, Jamnes <Jamnes.Cameron@nrc.gov>

Subject:

FW: tal king points for Clinton SIT findi ng Thanks Karla.

JER From: St oedter, Karla

Sent: Wednesday, August 08, 2018 7:42 AM To: Rutkowski, John <John.Rutkowski@nrc.gov>

Subject:

ta lking points for Clinton SIT findi ng

Jack, Karla

From : Mitman Jeffrey To : Kozak Laura Subject : Containment Procedures Date: Tuesday, August 14, 2018 2:3 1 :44 PM (b)(5)

(b)(5)

I

! Is there any way we can pu rsue this?

I thought I'd asked for, but cannot find the containment closure procedures. We have CPS 9065.01, but I cannot fi nd : CPS 1401.09 "Control of System and Equipment Status." If you don't have it, can you get it from Exelon?

Thanks.

Jeff Mitman

From: Hunter Christopher To: Kozak Laura Subject : RE: Clinton LER 461-2018-002 Date: Wednesday, August 15, 2018 8 :57:20 AM Got it. Thanks.

From: Kozak, Laura Sent: Wednesday, August 15, 2018 9:56 AM To: Hunter, Christopher <Christopher.Hunter@ nrc.gov>

Subject:

RE: Clinton LER 461-.2018-002 Approved by IFRB and so fa r no push back from the licensee. Report is going out soon with PD and risk considered to be TBD From: Hunter, Christopher Sent: Wednesday, August 15, 2018 8:54 AM To: Kozak, Laura <Laura.Kozak@nrc.gov>

Subject:

RE: Clinton LER 461-.2018-002 Thanks Laura . Is the PD definite?

From: Kozak, Laura Sent: Wednesday, August 15, 2018 8:50 AM To: Hunter, Christopher <Christopher Hunter@nrc gov>

Subject:

RE: Clinton LER 461-.2018-002 Chris Yes, we are working it. Jeff Mitman has t he lead. Hoping to complete in the next couple of weeks.

l(b)(5)

Laura From: Hunter, Christopher Sent: Tuesday, August 14, 2018 1:56 PM To: Koza k, Laura <La ura.Kozak@ nrc.gov>

Subject:

Clinton LER 461-2018-002 Laura, Are you working t his issue (https://www.nrc.gov/docs/ML1819/ML18199A106.pdf)? I wasn't on my rada r yesterday during the SRA call, but I thi nk this was the event you mentioned.

Than ks, Chris

From: Kozak Laura To : stoedter Karla: Phillips Charles Cc : Sanchez Santiago Elba : Sargis Daniel Subject : Clinton Flex reliability data Date: Friday, August 17, 2018 11 :26: 10 AM Attachments: Questions Response Final.pd!

FYI - I thought you might be interested.

As a part of the SOP and considering FLEX, we need to estimate the reliability of FLEX generators/pumps, etc. In PRA this is modeled as failures to start and failure to run (over the PRA mission time). We requested the actual operating experience from Clinton and received the attached document.

A couple of points:

(b )(5)

Laura

Question 6:

Please provide reliability data for FLEX equipment (number of starts, duration of runs, and number of failures to start or run). Please provide failure probabilities derived from the previous data. For equipment failures, please provide the associated condition report.

Response

The reliability data is provided below.

FLEX Diesel Generators - 1 FX01 KA and 1FX01 KB Demands from PM Tasks From April 1, 2016 to August 14, 2018, the FLEX Diesel Generators have a combined 14 demands and a total of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of run time from PM tasks.

One failure was reported during this time as documented in IR 2688011 . The Functional Failure determination is provided in the Maintenance Rule section below.

Based on the limited plant specific operational data to date, the following reliability rates are calculated:

FLEX DG FTS: 1 failure/ 14 demands = 7.2E-02/demand FLEX DG FTR: 0.5 failures (assumed) / 8 hrs= 6.3E-02/hour Using a 24-Hour mission time for the FLEX equipment, consistent with PRA Internal Events assumptions, the resulting failure probability would be:

FLEX DG FTR: 6.3E-02/hour

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months = 1.5 (NOTE: This term would be capped at 1 as a probability greater than 1 is a nonsensical result.)

This value is inappropriately conservative and is impacted by two attributes:

There is an assumed 0.5 failures included in the probability development when no actual run failures have occurred.

There is very little operating data to be used to develop a statistically meaningfiul probability FLEX Pumps - 1 FX01 PA and 1 FX01PB Demands from PM Tasks From April 1, 2016 to August 14, 2018, the FLEX Pumps have a combined 14 demands and a total of 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months of run time from PM tasks.

Two failures occurred during this time.

One failure is documented in IR 2686374 and occurred in June 2016. The condition described in the IR was not associated with a failure but with an extended unavailability associated with a PM task. This is not considered a failure for the PRA model. The Maintenance Rule Functional Failure determination is provided in the Maintenance Rule section below.

The second failure is documented in IR 04163408 and occurred in August 2018. This failure was a failure to start, and would be considered a failure in the PRA model. The Maintenance

Rule Functional Failure determination was not available as of the preparation of this document, but a brief description of the event is provided in the Maintenance Rule section below.

Demands from Other Activities The FLEX pumps are also used to support Operator train ing, when the equipment is operated in order to increase familiarity with the equipment. The following table summarizes the additional operation of the FLEX pumps for training. This provides an additional 8 demands and 20.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of run-time for the FLEX pumps for a total of 22 demands and 29.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of run time.

Run Date Demands Comment Hours Ops Training used to credit WO 1854794. Run time was 9/4/2015 1 not indicated on the PM Task so no credit was taken.

7/10/2015 1 2.2 Ops Training used to credit WO 1828639 NLO Training . Equipment Operation per 3862.02. Each 6/6/2018 1 3 run was 3-4 hours. Will use 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for data.

NLO Training. Equipment Operation per 3862.02. Each 6/13/2018 1 3 run was 3-4 hours. Will use 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for data.

NLO Training. Equipment Operation per 3862.02. Each 6/20/2018 1 3 run was 3-4 hours. Will use 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for data.

NLO Training. Equipment Operation per 3862.02. Each 6/27/2018 1 3 run was 3-4 hours. Will use 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for data.

NLO Training. Equipment Operation per 3862.02. Each 7/6/2018 1 3 run was 3-4 hours. Will use 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for data.

NLO Training. Equipment Operation per 3862.02. Each 7/11/2018 1 3 run was 3-4 hours. Will use 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for data.

No FLEX Pump failures during the Operator training runs have been identified to date.

Based on the limited failure data to date, the following reliability rates are calculated:

FLEX UHS Pump FTS: 1 failure/ 22 demands = 4.5E-02/demand FLEX UHS Pump FTR: 0.5 failures (assumed)/ 29.2 hrs = 1.7E-02/hour Using a 24-Hour mission time for the FLEX equipment, consistent with PRA Internal Events assumptions, the resulting failure probability would be:

FLEX UHS Pump FTR: 1.?E-02/hour

24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s= 0.41 This value is inappropriately conservative and is impacted by two attributes:

There is an assumed 0.5 failures included in the probability development when no actual run failures have occurred.

There is very little operating data to be used to develop a statistically meaningful probability Clinton Internal Events PRA Model 2

For the development of the FLEX equipment reliability data used in the Clinton Internal Events PRA model, no plant specific data was collected or used. The Clinton Internal Events PRA model of record, CL 117A, uses plant specific data gathered through December 3 1, 2016.

Given that data gathering for Clinton FLEX equipment did not begin until April 2016, there was an insufficient data population on which to base plant-specific probabilities. Therefore, the probabilities are based on NUREG/CR-6928 data (2015), adjusted as described below.

Equipment used as part of the FLEX strategies includes some permanently installed equipment (e.g., SF pumps used for the RPV injection strategy) and some portable equipment (e.g., FLEX pumps used for the SPC strategy). In the baseline risk assessment, the random failure probabilities of permanently installed equipment (e.g., SF pumps) are the same as those associated with other permanently installed components of the same type (i.e., using the equipment type code). For portable equipment, lacking sufficient plant specific data, the random failure probabilities are estimated as double those of similar, permanently installed, components, as identified below:

FLEX Mode Basic Event Prob Basis Comment EQuipment FLEX DGs are smaller and FLEX DG FTS 1FXDGPRIFLEX-A-- 1.23E-02 2x EOG FTS less complex than installed 480V EDGs.

FLEX DGs are smaller and FLEX DG 48hr EOG FTR 1FXDGPRIFLEX-X-- 6.15E-02 less complex than installed 480V FTR EDGs.

Supports SPC. RPV 2x DD Pump injection is via installed SF FLEX DD FTS 1FXPD-PRIFLEXA-- 6.30E-03 FTS (like FP pumps. Failure rates of the Pump pump) SF pumps are not increased.

Supports SPC. RPV 48hr DD injection is via installed SF FLEX DD FTR 1FXPD-PRIFLEXX-- 1.05E-02 Pump FTR pumps. Failure rates of the Pump (like FP pump) SF pumps are not increased.

The FTS and FTR terms were based on the generic data from NUREG/CR-6928 as modified as described in the CL 117 A MOR Data notebook.

Although the plant-specific data for Clinton's FLEX equipment is sparse, a comparison of the plant-specific reliability rates calculated using that data to the rates used in the Internal Events model is provided in the following table:

Probability Probability Based on FLEX Mode Basic Event Used in Plant Data Comment Equipment PRA through July 2018 FLEX DG FTS 1FXDGPRIFLEX-A-- 1.23E-02 7.2E-02 Within a factor of 6.

480V 3

Probability Probability Based on FLEX Mode Basic Event Used in Plant Data Comment Equipment PRA through July 2018 The plant data derived probability would exceed 1 FLEX DG FTR 1FXDGPRIFLEX-X-- 6.15E-02 1.0 which is an indication of 480V the inadequacy of the data collected.

FLEX DD FTS 1FXPD-PRIFLEXA-- 6.30E-03 4.5E-02 Within a factor of 7.

Pump Excessively conservative FLEX DD FTR 1FXPD- PRIFLEXX-- 1.05E-02 0.41 value from sparse plant Pump data Maintenance Rule Clinton elected to create Maintenance Rule functions for the FLEX equipment. These functions were implemented at Clinton in 2015. From the Clinton Maintenance Rule database:

FX-01 Function Function Title - FLEX UHS Water Pump

==

Description:==

The FLEX UHS Water Supply pump can be aligned to the DG building manifold to supply water to perform the following functions:

a) Division 1 or Division 2 Shutdown Service Water (SX) for Suppression Pool Cooling and Spent Fuel Pool Makeup b) Low Pressure Core Spray (LPCS) or Residual Heat Removal (AHR) train C injection headers for Suppression Pool or Reactor Pressure Vessel (RPV) Makeup.

c) Spent Fuel Pool Spray if required.

This Function is Low Safety Significant.

Function Failure Definition:

A failure is defined as the loss of the capability of any of the FLEX Pumps, Diesel Generators, or associated equipment to be able to provide the FLEX function .

FX-02 Function Function Title - FLEX Elect (FLEX Gen)

==

Description:==

FLEX Electrical Support (FLEX Generator) - A FLEX generator can be lined up to the Control Building FLEX Riser through either primary and alternate connections to support electrical distribution to 480 VAC Susses and 125 VDC Distribution for both Division 1 and Division 2 key equipment controls and critical parameter indications.

This Function is Low Safety Significant.

Function Failure Definition:

A functional failure is a failure of the FLEX diesels or other electrical distribution equipment which would render the entire FLEX electrical strategies unavailable .

4

FX-03 Function (NOT IN MR SCOPE):

Function Title - FLEX Spent FP Instr.

==

Description:==

The purpose of this equipment is to address the regulatory requirements set forth under NRG Order EA-12-051 with regard to reliable Spent Fuel Pool (SFP) Instrumentation. The NRG Order has been issued in response to the events that took place at Fukushima Daiichi on March 11 , 2011. This function was determined to not be in-scope for the Maintenance Rule and is provided for completeness of the FLEX Maintenance Rule information.

Functional Failures Based on a review of the IRs captured under the FLEX functions, three functional failures were identified, as listed below.

IR Number IR Subject Origination Date 2686374 lFX0lPA NOT AVAIILABLE DUE TO OIL CHANGE ISSUE 6/27/2016 2688011 lFX0lKA FLEX GENERATOR FAILED TO START DURING PM 6/30/2016 4163408 lFX0lPA FAILED TO START FOR ANNUAL PMS 8/10/2018 For IR 2686374, the functional failure determination is provided below:

This is a MRFF as during maintenance the condition was created where the pump was not available to perform its FLEX function. Per FX system MRule scoping "A failure is defined as the loss of the capability of any of the FLEX Pumps, Diesel Generators, or associated equipment to be able to provide the FLEX function." this therefore constitutes a MRFF against the FX-01 mechanical train function.

Based on a review of the IR, this issue was a condition where the FLEX pump was being maintained by a vendor. A pump oil change was part of the preventive maintenance being performed. The vendor failed to bring enough replacement oil to refill the pump resu lting in additional unavailability of th e FLEX pump for an additional day. This is not considered a failure but rather a continuation of the maintenance activity for the purposes of the equipment reliability data collection.

For IR 2688011 , the functional failure determination is provided below:

The battery causing the FLEX diesel to not start is a failure of the FLEX diesel to perform its FLEX function as a part of the electrical train. This constitutes a failure for the Electrical train FLEX function FX-02 where "A functional failure is a failure of the FLEX diesels or other electrical distribution equipment which would render the entire FLEX electrical strategies unavailable."

This would be considered a failure for the PRA model.

For IR 4163408, the functional failure determination has not yet been completed. The following is an assumption regarding this failure:

The governor control flashing, preventing the FLEX pump from starting, is a failure of the FLEX pump to perform its fu nction. This constitutes a failure for the FLEX pump function FX-01 where "A failure is defined as the loss of the capability of any of the FLEX 5

Pumps, Diesel Generators, or associated equipment to be able to provide the FLEX function".

This would be considered a failure for the PRA model.

6

From: Louden Patrick To: Kozak Laura: Stoedter Karla: Lara Juno Cc: Mitman Jeffrey: Phillips Charles: Sanchez Santiago Elba

Subject:

RE: Update on Clinton SOP Date: Monday, August 20, 2018 8:01 :01 AM Thanks for the update Laura.

I agree with your perspective on the FLEX stuff. We should more fully discuss how inspectors should consider factoring FLEX observations into the baseline. (BCs and SRAs)

Pat From: Kozak, Laura Sent: Friday, August 17, 2018 3:45 PM To: Stoedter, Ka rla <Karla.Stoedt er@nrc.gov>; Louden, Pat rick <Patrick.Louden@nrc.gov>; llara, Julio

Cc: M itman, Jeffrey <Jeffrey.M it man@ nrc.gov>; Phill ips, Charles <Charles.Phil lips@nrc.gov>;

Sanchez Sant iago, Elba <Elba.SanchezSantiago@ nrc.gov>

Subject:

Update on Cli nton SOP FYI We are actively working on the SOP evaluation for Clinton. No results yet but on track to support the commitment to complete the DRE by the end of August to support a SERP mid-September, if necessary.

We have received the licensee's evaluation, which concludes the finding is of very low risk significance with a delta GDF of approximately E-8/yr. We have also received answers to several questions we asked regarding containment closure, FLEX reliability, and training on FLEX and the Division 3 cross-tie. We plan to discuss the answers to those questions with the licensee next week to get a common understanding.

(b )(5)

From: Mitman Jeffrey To: Kozak Laura Subject : RE: Power Supply for Back-up Battery Charger 1DC11E Date: Thursday, August 23, 2018 4:58:51 PM I believe that Mike Antonelli has not had time to review all of the appropriate procedures.

The 480V MCC 1E is energized by CPS 4306.01P001, see Step 4.3.1.11.

However, I continue to be confused.

According to drawing E02-1DC06 the backup battery charger for the Div. 1 125V (b )(5)

Jeff Mitman From: Edom, Joseph T:(Contractor - GenCo- Nuc) [ma ilto:Joe.Edom@exeloncorp.com]

Sent: Thursday, August 23, 2018 1:48 PM To: Koza k, Laura <Laura.Kozak@nrc.gov>; Mitman, Jeffrey <Jeffrey.M itma n@nrc.gov>

Cc: Joe Edom - Jensen Hughes (JEdom@jensenhughes.com) <JEdom@jensenh ughes.com>; Wes Brinsfield (WBrinsfield@j ensenh ughes.com) <WBri nsfield@j,ensen h ughes.com>; Teagarden, Grant

<gteagarden@jensenhughes. com>; Antonelli, M ichael K.:(GenCo-Nuc)

Subject:

[Externa l_Sender] Power Su pply for Back-up Battery Charger lDCllE Laura and Jeff, Based on a review by Mike Antonelli:

1DC11 E is powered by non-vital power from aux building MCC 1E (Fed from unit sub 1M - 6.9kV 1B side).

Reviewing 4306.01 C001 , unit sub 1M or MCC 1E is not directly powered up by FLEX actions. It would take more ext ensive efforts to try and power t hese busses up.

The most likely path wou ld be t o power up the associat ed safety related 480V bus and restore that division's own battery charger.

Joe Edom I Senior Corporate Risk Management Engineer JENSEN HUGHES Advancing the Science of Safety One Trans Am Plaza Drive I Suite 200 I Oakbrook Terrace, IL 60181 (b)(6) O:+1630~627,22771C: ! * ! F: +1 630-627-2278 JEdom@jensenhuqhes com I www.iensenhuqhes com

++++++++++++++++++++++++++++++++++++++++++++++++

Exelon E-mail: joe.edom@exeloncorp.com This Email message and any attachment may contain information that is proprietary, legally privileged, confidential and/or subject to copyright belonging to Exelon Corporation or its affiliates ("Exelon"). This Email is intended solely for the use of the person(s) to which it is addressed. If you are not an intended recipient, or the employee or agent responsible for delivery of this Email to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this Email is strictly prohibited. If you have received this message in error, please immediately notify the sender and permanently delete this Email and any copies. Exelon policies expressly prohibit employees from making defamatory or offensive statements and infringing any copyright or any other legal right by Email communication. Exelon will not accept any liability in respect of such communications. -

EXCIP

From: Kozak Laura To: Mitman Jeffrey Subject : Clinton - HRA - Crosstie, FLEX, etc.

Date: Friday, August 24, 2018 8:53:00 AM Jeff, A few more thoughts on our discussion yesterday about modeling the cross-tie, etc.

{b )(5)

(b)(5)

Laura

From : Mitman Jeffrey To : Kozak Laura Subject : Clinton Questions Date: Sunday, August 26 , 2018 5:30:20 PM Laura, I have more questions for Exelon:

(b)(5)

Jeff Mitman

From : ~

To : ~

Subject:

Setit from Srjppwlg Toot Da te: Monday , Augu&t 27, 20 18 10:44:00 AM Attac hment s: -=a (b)(5)

Note to requester: The attachment to this email has been withheld in From: Kozak Laura its entirety under FOIA Ex. B5 (deliberative process privilege).

To : Mitman Jeffrey Subject : Clinton - items for discussion Date: Tuesday, August 28, 2018 5:16:00 PM Attachments: Clinton Shutdown SPAR model comme nts.docx Jeff Please see my comments/questions/items for discussion in the attached.

Thanks for all your hard work on this issue.

Laura

(b)(5)

From: Mitman Jeffrey To : Kozak Laura Subject : Clinton Event Tree Structure Date: Tuesday, August 28 , 2018 6:28:38 PM (b)(5)

Jeff Mitman

From: Mitman Jeffrey To : Kozak Laura Subject : Clinton Model Assumptions.docx Date: Tuesday, August 28 , 2018 7:02:33 PM Attachments: Clinton Model AssumfL~

Laura, attached is my working document for explaining the model. It is far from complete but it is a start.

Shortly, I'll upload a new version of the model onto SharePoint.

(b )(5)

Jeff Mitman

Clinton Shutdown Model Assumptions

Time to boil (TTB) = 4.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , based on Exelon document CL-SDP-010 Rev. 1

Time to core uncover (TTCU) = 23.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , based on Exelon document CL-SDP-010 Rev. 1

Core uncovery is the normal at-power surrogate for core damage. During shutdown, core damage is not expected between 1/3 and 1/2 core height which is somewhat after core uncovery, therefore, using core u ncovery as a surrogate for core damage is somewhat conservative.

Unavailable and non-recoverable equipment due to t est and maintenance (T&M):

o EOG lA (note 4160v AC bus lAl is energized and available as long as offsite power is available - because the associated EOG is unavailable, this bus will de-energize on loss of offsite power) o 480v AC bus lA o 480v AC bus A o NSPS 120v Power distribution panel bus A o 125v DC battery charger lA (which is feed from aux. building MCC lAl)

Assumed available equipment o 480v AC aux. building bus 1L o 480v AC aux. building bus lM o 480v AC aux. building bus 1D o 480v AC aux. building bus lE (f eed to 125v DC battery charger lF) o 125v DC battery charger lF (feed from 480v AC aux. building bus lE)

According to drawing E02-1DC06 (125v DC & uninterruptible power supply systems) the normal feed to 125v DC bus lA is via battery charger lA. Per the licensee, this battery charger was not available due to T&M . Per the same drawing, the backup supply to 125v DC bus lA is from swing battery charger lDCllE from aux. building 480v MCVC lE (1AP28E). Per drawing E02-1AP03 (electrical load diagram), the 1DC25E battery charger is on 480v AC aux. building bus 10 (1AP14E),l(b)(5) I l(b)(5)

The at-power Clinton SPAR model has basic event (BE) failure probabilit ies for many of the valves that need to be manipulated by the FLEX procedures. These BE failure probabilities are based on data which include failure to open or close based on AC or DC power being available to operate the valve. During the ELAP condition, electrical power may or may not be available to (b)(5) ooerate the valve. I I (b)(5) I (b)(5 ) ................................... l...,:____;_

- _ _ _ _ __.I Without electrical power these contributions to the failure probability are not possible. This should lower the valve failure probabilities in the model. However, t he valves can still be opened manually by an equipment operator (EO) at the valve operator without (b)(5) electriq,i!,.p9wer.. ..

High level guidance provided by 4306.01P017 Strategy Support Core Cooling Containment Spent Fuel Pool 1

Lineup FLEX generator to Division 1 or 2 480

Run available ECCS waterleg pumps

Set Primary Containment Same as Mode 1,2,3 VAC per 4306.0lPOOl FLEX Elect rical

Pressurize and run RCIC

Establish suppression pool (makeup, ventilate)

Connections

Makeup to RPV per 4306.01P004 FLEX cooling per 4306.01P003 FLEX

Lineup FLEX pump to resto re Div 1 or 2 SX Low Pressure RPV Makeup Suppression Pool Cooling.

per 4306.01P002 FLEX UHS Water Supply

Open an SRV Procedure List Revision Procedure Current Title Controlling Comments Number Revision during PD 4006.01 Loss of SOC Sc Sc 4200.01 Loss of AC Power 2Sa 2Sa 4200.01C002 DC Load Shed during a 580 Sa Sa 4303.01P023 Cross-Connecting Div. 3 DG 2b 2b to Div1(2)ECCS Electrical Busses 4306.0lPOOl FLEX Electrical Connections Od Od Directors operat or to DC load shed per 4200.01C002 4306.01P002 FLEX UHS Water Supply Oe Oe Takes about 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to perform per 4306.01P017 4306.01P003 FLEX SPC 4306.01P004 Makeup to RCS Strategy 1 (to be used in CSD) below steps are stipulated in 4306.0lPOl7:

Run ECCS waterleg pumps

Pressurize RCS and run RCIC

Makeup to using this procedure

Open SRV 4306.01P017 ELAP During Modes 4 and 5 0 0 Supplies high level guidance. Including:

"Take action to establish primary containment integrity."

Consider using ECCS waterleg pumps for RPV injection using power from FLEX DG Supplies guidance on using 3 strategies depending on POS. For CSD, directs operator t o Strategy 1 (see table above) 4411.06 Emergency Containment 6b 8/5/18 ??

Venting, Purging, and Vacuum Relief

Table X S1 ,f D,

- -- ----- -- --- -- - - - ----- -- -- HRAR, M ean Mean Total Time Time Human Error Event Description Procedure Diagnosis Action Mean Needed Available HEP HEP HEP SD-XHE-XM-ISDC Isolate SDC after LOSDC 4006.01 SD-XHE-XM-XTIE Cross Tie Div. 3 and Div. 2 Electrical 4303.01P023 4.0E-2 6.0E-1 6.4E-1 Operator Fails to Setup and Run FLEX SD-XHE-XM-FELEC 4306.0lP00l 2.0E-2 2.3E-1 2.SE-1 DG and Electrical Distribution Operator Fails UHS Water Supply using SD-XHE-XM-FUHS 4306.01P002 2.0E-3 1.lE-1 1.lE-1 FLEX Operator Fails Suppression Pool SD-XHE-XM-FSPC 4306.01P003 1.0E-3 2.3E-1 2.3E-1 Cooling using FLEX Injection into RCS using FLEX Diesel SD-XHE-XM-FRCS Driven Pumps (4306.01P002 Sections 4306.01P004 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 2.0E-3 1.lE-1 1.lE-1 4.3 and 4.4)

SD-XHE-XM-DCLS Operator performs DC Load Shed 4200.01C002 lhour 4.0E-2 2.0E-2 6.0E-2 Operator Fails to Perform Firewater SD-XHE-XM-FWS ? 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 10 hours 1.2E-1 Injection into RCS Operator Fails to Operate RCIC during SD-XHE-XM-FRCIC ? 2.0E-3 7.SE-1 7.SE-1 ELAP from Shutdown Operator Fails RCS Injection using FLEX 4306.01P004 SD-XHE-XM-FINJ 1 Hour 2E-3 2E-3 4E-3 SPC (4306.01P004 Section 4.1) Section 4.1

FLEX AC Electrical Fault Tree FLEX Electrical System FLEX-ELEC FLEX Diesel Generators FLEX Bus Equipment Failures ACP-FLEX-BUS FLEX-ELEC4 2.29E-05 Operator Fails to Setup and Run FLEXDG and Electrical Distribution SD-XHE-XM-FELEC FLEXDiesel l(permanentlyinstalled) FLEX Diesel 2 (portable) 3.20E-01 FLEX Electrical Connectio n Fails due to Design or Construction FLEX-ELEC41 FLEX-ELEC42 FLEX-ELEC-CONNECT S.00E-02 CCF of FLEX Diesel Generators 1 and 2 to Run FLEX Diesel Generator 1 Fails to Run FLEX Diesel Generator 2 Fails to Run EPS-FDGN-CF-FR 2.37E-03 EPS-DGN-FR-FDGl EPS-DGN-FR-FDG2 CCF of FLEX Diesel Generators 1 and l.S0E-01 l.S0E-01 2 to Start FLEX Diesel Generator 1 Fails to FLEX Diesel Generator 2 Fails to Start Start EPS-FDGN-CF-FS l.lSE-05 EPS-DGN-FS-FDGl l.20E-03 FLEX Diesel Generator 1 Unavailable EPS-DGN-FS-FDG2 l.20E-02 FLEX Diesel Generator 2 Unavai lable u

because of Test or Maintenance because of Test or Maintenance EPS-DGN-TM-FDGl EPS-DG N-TM-FDG2 1.48E-02 1.48E-02 u FLEX Diesel 2 (portable) Fails due to ImproperTransport or Setup EPS-DGN-XR-FDG S.00E-02 u

FLEX Suppression Pool Cooling Fault Tree FLEX Suppress ion Pool Cooing FSF I

I I I I FSPumps NotAvailable RHRHeatExchangers NotAvailable FLEX Electrical System CCF OF SF MOPS TO RUN FLEX*ELEC SF*MOP-CF*FR FFC2 FFC8 External 9.SIE-07 I

PUMP A IS UNAVAILABLE y

I PUMPB IS UNAVAILABLE y

CLINTON FLEX SPC LOOP B I S SD-FUHS FLEX UHS CCF OF SF MOP'S TO START SF*MOP*CF*STRT External 4.58E*06 UNAVAILABLE FSPC-B 6 SF COOLING SUCTION MOV F004 FFC64 FFC73 External SF*MOV*CC*F004 T 7 CLINTON FLEX SPC LOOP A IS 8.16E*04 UNAVAILABLE SF COOLING SUCTION Manual F003 FSPC*A Suppression Pool Cleant.p ard Suppress ionPoo I Cleant.p ard External Transfer MDP lA FAILS TO START Transfer MOP 1B FAILS TO START SF*VLV-CC*F003 SF*MOP*FS*IA SF*MOP*FS*lB 6 8.16E*04 SF COOLING Olscharge AOV F011 1.09E-03 1.09E-03 Suppress loIn Poo l Cleaiw ard Suppress loin Pool Cleaiw ard Trans fer MOP l A FAILS TO RUN Transfer MOP 1B FAILS TO RUN SF*AOV-CC*FOll 7.55E-04 SF-MOP-FR-IA SF*MOP*FR-1B SF COOLING Valve F041 9.00E-05 9,00E-05 SF MDP6A OISCHARGECH ECK SF MOP 6B DISCHARGE CHECK VALVE FAILS TO OPEN VALVE FAILS TO OPEN SF*MOV*CC-F041 8.16E*04 SF*CKV*CC*6A SF*CKV-CC-66 Operator Fails Suppressi<>n ll:>ol 9.24E*06 9.24E*06 Cooling using FLEX SFMDP IAUNAVAILABLEDUETO SF MDPIB UNAVAILABLEDUETO TEST AND MAINTENANCE TEST AND MAINTENANCE SD*XHE* XM-FSPC 3.02E*Ol SF*MDP*TM*lA SF*MDP*TM*IB FLEX Electrical Connection Falls 4.56E*03 4.56E*03 SF COOLING Dlscharge MOVFOIOA SF COOLING 0Ischa rge MOV FOlOB FLEX*ELEC*CONNECT 5.00E*02 SF-MOV-CC-FOl<l'\

8.16E-04 SF*MOV-CC-FOIOB 8.16E*04 u u u

FLEX Ultimate Heat Sink System Fault Tree

,~ --FL....E_X_U_H__S_S_ys- t-em

- (4

_3__

0_6.~0-l P--0-02

__)_,

SD-FUHS FLEX Engine Driven Pumps SSWA TIE TO PSW MOV SSW 14A FAILS TO CLOSE SSW-MOV-OO-SSW14A SD-FUHS! 8.16E-04 Operator Fails to Setup and Run FLEX Ult imate Heat Sink System (4306.01P002)

SD-XHE-XM-FUHS FLEX Pump 1 Fails FLEX Pump 2 Fails 1.l0E-01 FLEX PUMPS FAIL FROM COMMON CAUSE TO RUN SD-FUHS10 SD-FUHS11 FLEX-EDP-CF-FR 6.12E-03 FLEX PUMPS FAIL FROM COMMON CAUSE TO START FLEX ENGINE DRIVEN PUMP 1 FAILS FLEX ENGINE DRIVEN PUMP 2 FAILS TO RUN TO RUN FLEX-EDP-CF-FS 2.90E-04 FLEX-EDP-FR-1 FLEX-EDP-FR-2 FLEX Diesel Driven Pump Connectio n 2.00E-01 2.00E-01 Fails due to Design or Construction FLEX ENGINE DRIVEN PUMP 1 FAILS FLEX ENGINE DRIVEN PUMP 2 FAILS TO START TO START FLEX-EDP-CONNECT 5.00E-02 FLEX-EDP-FS-1 FLEX-EDP-FS-2 FLEX Manifold Iso latio n Valve Fails l.00E-02 l.0OE-02 Closed u u FLEX-MV-CC-1XF003 4.59E-04 FLEX Pipe Manifold Isolation Valve to SXDiv.1 or 2 Fails Closed FLEX-MV-CC-1XF001C 4.59E-04 FLEX Water Injection to SX Valve Div. 1 o r 2 Fails Closed SSW-MV-CC-SXF354 4.59E-04 u

From: Mitman Jeffrey To: Kozak Laura Subject : RE: Clinton - HRA - Crosstle, FLEX, etc.

Date: Tuesday, August 28, 2018 6:20:53 PM Laura, if I understand your position, I agree with it. My thinking and approach is as follows:

(b)(5)

Jeff Mitman From: Kozak, Laura

Sent: Friday, August 24, 2018 9:53 AM To: M it ma n, Jeffrey <Jeffrey.M itma n@nrc.gov>

Subject:

Clinton - HRA - Crosstie, FLEX, etc.

Jeff, A few more thoughts on our discussion yesterday about modeling the cross-tie, etc.

(b)(5)

From: Kozak Laura To: Mitman Jeffrey Subject : RE: Clinton Model Assumptions.docx Date: Wednesday, August 29, 2018 6:52:25 AM Do you have some time to ta lk tomorrow afternoon?

From: M itman, Jeffrey Sent: Wednesday, August 29, 2018 7:49 AM To: Koza k, Laura <Laura.Kozak@ nrc.gov>

Subject:

RE: Clinton Model Assumptions.docx Sounds like a plan.

Jeff Mitman From: Kozak, Laura Sent: Wednesday, August 29, 2018 7:14 AM To: Mitma n, Jeffrey <Jeffrey.Mjtman@nrc gov>

Subject:

RE: Clinton Model Assumptions.docx Jeff I'd like to take the following approach. Tell me what you think Inform NRC management that we currently think the findi ng is GTG but we are not yet complet e.

Begin development of a SERP package for a SERP meeting in mid-September as planned. I'm planning to send an email to regional managers today.

I don't thin k the cha nges to t he event tree that you brought up are necessa ry at t his point. I think we have a pretty well deve loped sense of w hat is driving the risk significance so let's focus o n the points of modeling t hat we think are important.

Schedule both a call with Exelon and a trip to Clinton. The ca ll to discuss the cross-tie and the t rip to discuss in detailed risk evaluation.

Continue ou r discussions and refinement of the risk eva luation. Regarding the Clinton specific IEF, I t hin k a sensitivity eval uation is t he place to st art.

Laura From: M itman, Jeffrey Sent: Tuesday, August 28, 2018 8:03 PM To: Kozak, Laura <Laura .Kozak@ nrc.gov>

Subject:

Clinton Model Assumptions.docx

(b)(5)

(b )(5)

From:

To:

Subject:

Date:

Attachments:

l!wl!..I.Aw:I FW: RE: Model Punch list and Noles 09-05-2018.xlsx ThurSday, Septembef 06, 2018 4:09:52 P'M

~

Laura, fyi.

Jeff Mitman From: Robert F. Buell [2]

Sent: Thursday, September 06, 2018 5:02 PM To: Mitman, Jeffrey <Jeffrey.Mitman@nrc.goV>

Subject:

[External_Sender) RE: Model Punch List and Notes 09-05-2018.xlsx Je ff, (b)(5)

This can be modified to something like:

(b)(5)

(b)(5) .__,...=__________.I FYI, I will be our of the office tomorrow and all of next week. Hope this helps.

From: Mitman, Jeffrey fmailto* Jeffrey Mitmao@nrc gov)

Sent: Wednesday, Sept ember 05, 2018 4 :46 PM To: Robert F. Buell <robert buell@1ol *Av>

Cc: Kozak, l aura

Subject:
Model Punch List and Notes 09*05*2018.xlsx Bob, on the spreadsheet tab labeled "ET Top Logic" is a table. The table describes each of the ET tops: name, current top logic solving method, current quantification and comments. Two issues that I'd like to discuss in more on Thursday. 1} What do you recommend for the solving method?
2) Why is the SD-ALT-HEAT quantifying to 1.1 E-2 instead of 1.0?
The ET structure is the same as you supplied to me several weeks ago. However, some of the FTs have been modified to credit FLEX. The SD*
ALT-HEAT FT has not been touched.
I'll send the model in a separate email.
Thanks.
Jeff Mitman
From: Kozak Laura To: Mitman Jeffrey
Subject:
Clinton - Recovery of Division 2 DG Date: Friday, September 07, 2018 7:48:00 AM Jeff The evaluation contains the following statement:
Procedures are in place and will be used. Plenty of cues. Designated EO familiar with actions. DG will start when lockout relay is reset (at end of actions included in procedure) . (Mike Antonelli, 6/21 / 2018)
NOTE: Above says "DG will start when lockout relay is reset"... That is not technically true if DC load shedding has opened Circuit 13. According to Mike Antonelli (SRO), 7/9/2018: 1) "We have trained in the simulator for partial load sheds when you think you can restore the engine. For example, a scenario where we had the DG heat exchanger cooling valve fail to open, we will load shed, but not load shed the DG breaker if we didn't need to so we can get someone in the field to open the cooling valve locally/manually."
(b)(5)
Laura
Inspection Finding Review Board - Issues Under Development Discovery IFRB Date Issue IFRB Conclusion Open/Closed/Status Date Chair Non Responsive (b)(5)
Non Responsive
EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:
Clinton Exelon Docket Number(s): EA Number: EA-18-104 50-461 (b )(5)
Issue Date:~ Exh1-1 0609.0STP
(b)(5)
Issue Datei(b )(S) I Exh1-2 0609.0STP
(b)(5)
Issue Date: ~ Exh1-3 0609.0STP
(b)(5)
Issue Date: ~ Exh1-4 0609.0STP
(b)(5)
Issue Date: l(b )(S) I Exh1-5 0609.0STP
(b )(5)
Issue Date: ~ Exh1-6 0609.0STP
(b)(5)
Issue Date: ~ Exh1-7 0609.0STP
(b)(5)
Issue Date: ~ Exh1-8 0609.0STP
(b)(5)
Exh1-9 0609.0STP
(b)(5)
Issue Date: l(b )(5) I Exh1-10 0609.0STP
(b )(5)
Issue Date: ~ Exh1-11 0609.0STP
(b)(5)
Issue Date: ~ Exh1-12 0609.0STP
(b)(5)
Issue Date: ~ Exh1-13 0609.0STP
(b)(5)
(b )(5)
Issue Date Exh1-14 0609.0STP
(b)(5)
Issue Date: (b )( 5) Exh1-15 0609.05TP
(b)(5)
Issue Date: l(b )(S) I Exh1-16 0609.0STP
(b)(5)
Issue Date: (b)(5) Exh1-17 0609.0STP
Issue Date: ~ Exh1-18 0609.0STP Issue Date: ~ Att1-1 0609.0STP Note to requester: The attachment was processed in a previous document in the final release . The docum ent From : Kozak Laura is not included aQain here.
To : Mitman Jeffrey Subject : draft SERP package Date: Sunday, September 09, 2018 10:15:50 AM Attachments: Clinton EOG Unavailability SERP.docm Jeff I put a draft SERP package on t he share point site and att ached it here. I have writ ten up the background material, inclu ding assum pt ions, refe rences, differences w ith the licensee, etc. I need to complete th is document and submit it to ou r enforceme nt staff on Thursday. So please take a look if yo u can and comment or ed it as necessary.
I intend t o comp lete this document on Wed nesday/Thursday w ith our recommendation and basis.
know t hi s is tig ht but I f eel like we are almost there .
La ura
From: Dahbur Alan Note to requester: Attachment is a To: Hateez ljaz non-responsive record due to Cc: Daley Robert: Sanchez Santiago Elba: Sargis Daniel clarifying the request to exclude Subject : FW: Clinton Cross-tie procedure review licensee originated documents.
Date: Monday, September 10, 2018 2:27:17 PM Attachments: 4303,01 P023 /002),pdf Bob, Jesse has agreed to look into this issue to help DRP.
From: Sa nchez Santiago, El ba Sent: M onday, September 10, 2018 12:45 PM To: Dahbur, Alan <Alan.Dah bu r@nrc.gov>
Cc: Koza k, La ura <Laura.Kozak@ nrc.gov>; M itman, Jeffrey <Jeffrey. M it man@nrc.gov>; Sargis, Dan iel
<Daniel.Sa rgis@nrc.gov>; Stoedter, Karla <Karla.Stoedter@ nrc.gov>
Subject:
Clinton Cross-tie procedure review Alan, We are requesting your assistance in reviewing the attached procedure to determine whether it can be performed/completed with no AC or DC power. Below is some background information on why we are reviewing this procedure to provide some context into what we are looking for:
Background:
In May 2018, during the refueling outage, the licensee found the starting air for the Division 2 EOG was isolated. When this condition was discovered the Division 1 EOG was tagged out for maintenance. As a result of this condition, the region sent out a special inspection team to assess the issue. The team identified multi le violations one of which re uired a
- -o_ =_J=js=
(b)(S) - -,:::;;;d;;;;;et;;;:;a;;;:iJ-~::: _ k=e=v= -......!::::::====--=
-a=lu=.a:.:..tio.:.:n..... ---=---=-*-=-=-=**=***=...=
.-*-=
--=
-*=*--=-==========::::!.......,
(b)J Questions:
(b )(5)
Timeline:
The SERP is currently scheduled for Thursday, September 20. Ou r conclusions from this review will feed into the significance determination. Therefore we are requesting a response ASAP , but by Wednesday, September 1i hthe latest to allow the SRA's to incorporate the conclusions into their analysis. Let me know if this timeline is doable.
Also , let me know if you need any additional information for your review or if you have any questions for us.
Thanks for your help,
'E{ba Sanchez Santiago Seni or Reside nt Inspector Clinton Power Station RIII/D RP/ Branch 1 (217) 935-9521
From : Stoedter Karla To : Kozak Laura Subject : RE: Clinton SERP Date: Monday, September 10, 2018 5:01 :43 AM I don't have any major comments. I did notice that the SERP package "cover sheet" seems to want a summary of the information contained further in the document. I'm not sure how well we will be able to summarize the information due to the length of the violation and all of the assumptions that you had to make to perform the DRE. Looks like I will need to add this information prior to giving the package to EICS. I'm tempted to just refer to the sections containing the information. What are your thoughts?
From: Kozak, Laura Sent: Sunday, September 09, 2018 10:19 AM To: Stoedter, Karla <Karla.Stoedter@nrc .gov>
Subject:
Clin ton SERP Hi Karla This is very draft but I thought I would give you an opportun ity to read/comme nt/q uestion now, si nce we are on such a tight sc hedule to complete the work and the package t his week.
It does not yet have a bottom lin e recomm endation (i. e., no color or num ber yet) as we are still fi nali zing the ana lysis and it co uld still cha nge as a resu lt of our visit to Clint on Monday and Tuesday.
(b)(5)
Laura
From: Hafeez liaz To : Dahbur Alan : Sanchez Santiago Elba: Stoedter Karla : Kozak Laura : Hanna John Cc : Daley Robert : Robbins John : Sargis Daniel Subject : Clin ton Questions.docx Date: Tuesday, September 11, 2018 3:25:35 PM Attachments: Clinton Ouestions.docx All ,
Please call if you have additional questions.
Thanks
Background:
In May 2018, during the refueling outage, the licensee found the starting air for the Division 2 EOG was isolated. When this condition was discovered the Division 1 EDG was tagged out for maintenance. As a result of this condition, the region sent out a special inspection team to assess the issue. The team identified multiole violations one of which required a detailed risk evaluation. I l __ (b)(5)_. .
(b)(5)
Questions:
(b)(5)
Timeline:
The .SERP is currently scheduled for Thursday, September 20. Our conclusions from this review will feed into the significance determination. Therefore we are requesting a response ASAP, but by Wednesday, September 12th the latest to allow the SRA's to incorporate the conclusions into their analysis. Let me know if this timeline is doable.
Also, let me know if you need any additional information for your review or if you have any questions for us.
Given:
The site is experiencing a loss of all off-site power.
Division 1 diesel generator is under maintenance and therefore not recoverable
Division 2 diesel generator does not start due to the isolation of the air start storage tank
Division 1 and Division 2 DC power is available from station batteries
Division 1 and Division 2 inverters are available (instrumentation]
Division 1 and Division 2 battery chargers are not available
No other equipment is out of service or unavailable Ql Would the licensee need AC power to accomplish this procedure?
Response: Based on the information provided, AC power is not needed to implement procedure CPS 4303.01 P023, "Cross-Connecting Div 3 to Div 2 ECCS Electrical Busses."
02 Would the licensee need DC power to accomplish this procedure?
Response: Yes, DC power is needed in order for equipment to be manipulated from the control room.
Procedure CPS 4303.01P023, "Cross-Connecting Div 3 to Div 2 ECCS Electrical Busses," is written with the assumption that DC power will be available. Under the assumptions stated above, DC power is expected to be available.
Additionally, while the procedure directs manipulation of equipment from the control room, equipment may be manipulated in the field to accomplish the intent of the procedure without DC power. It would likely take significantly more time to implement manually, but ii could be done.
03 Can lockout relays be reset manually with no power?
Response: Yes, in general this can be done manually. We did not specifically review vendor manuals for the lockout relays.
04 Is manually resting the lockout relays a complicated evolution?
Response: No, this is typically a single hand switch manipulation.
05 What would happen when [off-site] power is restored to the relay?
Response: Restoration of power to the switchyard and then to the reserve transformer will not impact operation of plant equipment after buses have been isolated from the reserve transformer at step 1.2.
Connections to the main transformer are also isolated at step 1.2, DC control power fuses are removed after opening to preclude inadvertent closure to a source of off-site power. Reconnecting to off-site power, once available, is not discussed in the procedure.
06 After manually resetting the lockout relay are they capable of actuation?
Response: It is possible that transformer protection systems may still have the potential to open main and reserve feed breakers associated with the bus in use, 1ET4. Additionally, as the Division 3 diesel generator is smaller than the Division 2 generator, it is possible that, if control room staff are not cautious when applying loads, Division 3 could trip. We would need more information to be able to discuss this question with more detail.
From: Murray Robert To : Phillips Charles: Karla Stoedter /Karla Stoedter@nrc gov}
Cc: Louden Patrick: Lara Ju!io: Chandra\bil Prema: Draper Jason: Mitlyng Yiktoria Subject : RE: Clinton SIT report is discussed in Lochabum"s blog Date: Tuesday, September 11, 2018 11 :35:00 AM (b)(5) ReadingLochbaum'sblog onthis issueJ (b)(5)
Chuck and Karla - nice job crafting the report into a final product for an intrusive inspection that accomplished what we intended.
Rob From: Cha ndrathil, Prema Se nt: Tuesday, September 11, 2018 8:25 AM To: West, Steven <Steven.West@nrc.gov>; Roberts, Darrell <Da rrell.Roberts@ nrc.gov>; Louden, Patrick <Patrick.Loude n@nrc.gov>; Lara, Ju lio <Ju lio.Lara@nrc.gov>; O'Brien, Kenneth
<Ken net h.O'Brien@nrc.gov>; Shua ibi, Mohammed <Mohammed.Shuaibi@n rc.gov>; Heck, Jared
<Jared.Heck@nrc.gov>; Giessner, John <John.Giessner@nrc.gov>; Lipa, Christ ine
<Christ ine.Lipa@nrc.gov>; Stoedter, Ka rla <Ka rla.Stoedter@nrc.gov>; Riemer, Kenneth
<Kennet h.Riemer@n rc.gov>; Sa nchez Santiago, Elba <Elba.SanchezSant iago@nrc.gov>; Sargis, Daniel <Daniel.Sa rgis@nrc.gov>; Phi ll ips, Charles <Cha rles.Phillips@ nrc.gov>; Murray, Robert
<Robert.Murray@nrc.gov>; Draper, Jason <Jason.Draper@nrc.gov>; Kozak, Laura
<Laura.Kozak@n rc.gov>; M itman, Jeffrey <Jeffrey.Mitman@ nrc.gov>
Cc: M itlyng, Vikt oria <Viktoria.M it lyng@nrc.gov>
Subject:
Clinton SIT report is discussed in Lochabum 's blog FYI-Lochbaum talks about the Clinton special inspection and recently issued report in his blog.
bttps://allthingsnudear.org/ dlochbaum/ clioton-power-problems Prema Prema Chandrathil Public Affairs Officer
U.S. NRC Reg ion Ill 630-829-9663
From: Kozak Laura To : Louden Patrick: Stoedter Karla Cc: Lara Juno: Hanna John: Sanchez Santiago Elba: Sargis Daniel Subject : Clinton SOP update Date: Wednesday, September 12, 2018 11 :29:42 AM We had a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months meeti ng yesterday w it h Exelon PRA ana lysts and present ed t he cur rent r isk model.
The event tree, fau lt t rees, assumptions, and human reliabi lity analysis were discussed at length.
The licensee provided a significant amount of feedback and asked us to consider some alternate assumptions. I believe t he licensee understands our model. We will not be able to consider the 1
feedback by t omorrow's deadline for subm itt ing a SERP package and we also can t project t he outcome with alt ernate considerations without doing further review.
(b)(5)
- --t-- - - - - - - - - - - - - - -
(b)(5) ................ L,___ _ _ _ _...,~ eff has a briefing of his manageme nt tomorrow morning and I will part icipate.
Karla and I talked t his morni n and Ian to meet with Pat tomorrow on the status and look for a (b)(5) ................de.c.is.ion.toeithel'..J.- - - - - - - - - - - - - - - -
b 5 (b)(5) IThe licensee estimated (b)(5)
(b)(5)
(b)(5) ...... --- . =:....J This is not t he only influe ntia l assumption.
(b)(5)
From: Kozak Laura To: stoedter Karla: Mitman Jeffrey
Subject:
draft Clinton SERP package Date: Wednesday, September 12, 2018 2:10 :05 PM Attachments: Clinton EOG Unavailability SERP.docm Jeff, Karla Ta lked with both of you today about where we are at with t he DRE and the recent significant feedback from the licensee.
If we choose to move foreward to a SERP, I developed the attached draft SERP package based on todays knowledge and ris k insights. It discusses the current DRE as consistent with t he pha se 2 resul t and acknowledges that HRA is driving the risk and will contin ue to be uncertain.
Please let me kn ow if you have comments/questions.
If we decide to move forward consistent with the original plan, this package must be submitted tomo rrow .
Jeff - FYI. Pat was in HQ but leaving today. Gave him a head s up on the status. Karla and I pla n to meet with him tomorrow afternoon.
Laura
EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:
Clinton Exelon Docket Number(s): EA Number: EA-18-104 50-461 (b)(5)
Issue Datej(b)(5) Exh1-1 0609.0STP
(b)(5)
Issue Date: l(b )(S) I Exh1-2 0609.0STP
(b )(5)
Issue Date: ~ Exh1-3 0609.0STP
(b)(5)
Issue Date: ~ Exh1-4 0609.0STP
(b )(5)
Issue Date: l(b )(5) I Exh1-5 0609.0STP
(b)(5)
Issue Date: l(b )(S) Exh1-6 0609.0STP
(b)(S)
Issue Date:~ Exh1-7 0609.0STP
(b)(5)
Issue Date: l(b)(5) I Exh1-8 0609.0STP
(b)(S)
Issue Date: E==:] Exh1-9 0609.0STP
(b)(5)
Issue Date: l(b )(5) I Exh1-10 0609.0STP
(b)(5)
Issue Date: ~ Exh1-11 0609.0STP
(b )(5)
Issue Date: ~ Exh1-12 0609.0STP
(b )(5)
Issue Date: ~ Exh1-13 0609.0STP
(b)(5)
Issue Date: ~ Exh1-14 0609.0STP
(b)( 5)
Issue Date: (b)(5) Exh1-15 0609.05TP
(b)(5)
Issue Date: (b )(5) Exh1-16 0609.0STP
(b)(5)
Issue Date: l(b)(5) Exh1-17 0609.0STP
Issue Date: ~ Exh1-18 0609.0STP Issue Date: ~ Att1-1 0609.0STP From: Kozak Laura To : Mitman Jeffrey Subject : RE: Clinton lnop Both EDGs SD Pre SERP 09-13-18 (0) .pptx Date: Wednesday, September 12, 2018 5:34 :57 PM (b )(5)
From: Mitman, Jeffrey Sent: Wed nesday, September 12, 20 18 6 :29 PM To: Ko zak, Lau ra <Laura.Kozak@ nrc.gov>
Subject:
Clinto n lnop Bot h EDG s SD Pre SERP 09-13-18 (0) .pptx Laura, this is what I have so far for tomorrow's meeting. I'll continue to work on it tonight/tomorrow prior to the discussion.
Jeff
From : Kozak Laura To : Mitman Jeffrey Subject : RE: Clinton lnop Both EDGs SD Pre SERP 09-13-18 (0) .pptx Date: Wednesday, September 12, 2018 5:41:24 PM One ot her comme nt (b)(5)
From: Mitman, Jeffrey Sent: Wednesday, Se ptem ber 12, 2018 6 :29 PM To: Kozak, La ura <Laura .Kozak@ nrc.gov>
Subject:
Clinto n lnop Both EDGs SD Pre SER P 09-13-18 (0).pptx Laura, this is what I have so fa r for tomorrow's meeting . I'll continue to work on it tonight/tomorrow prior to the discussion .
Jeff
From: Kozak Laura To: Hanna John Subject : RE: Clinton Questions.docx Date: Wednesday, September 12, 2018 8:46:49 AM They were Jeff's questions that Elba wrote up and we asked for DRS electrical help, which is why the DRS inspectors provided the answers.
From: Hanna, John Sent: Wednesday, September 12, 2018 8:44 AM To: Kozak, Laura <Laura.Kozak@nrc.gov>
Subject:
RE: Clinton Questions.docx
Laura, I was confused by the document that was sent out. Who wrote it? Are these Jeff Mitman and your questions to the licensee? Not sure what it was ... and the e-mail distribution didn't make sense to me either .. . if this related to the SOP issue.
John From: Kozak, Laura Sent: Tuesday, September 11, 2018 3:59 PM To: Hafeez, ljaz <ljaz.Hafeez@nrc.gov>; Dahbur, Ala n <Alan.Dahbur@nrc.gov>; Sanchez Santiago, Elba <Elba.SanchezSantjago@nrc.gov>: Stoedter, Karla <Karla.Stoedter@nrc.gov>; Hanna, John
<John.Hanna@nrc.gov>
Cc: Da ley, Robert <Robert.Daley@nrc.gov>; Robbins, John <John.Robbjns@nrc.gov>; Sargis, Daniel
<DanieLSargjs@nrc.gov>
Subject:
RE: Clinton Questions.docx Thank you ! Very hel pful.
Laura From: Hafeez, ljaz Sent: Tuesday, September 11, 2018 4:26 PM To: Dahbur, Alan <Alan Dahbur@nrc gov>; Sanchez Santiago, Elba <Elba SanchezSantjago@nrc gov>;
Stoedter, Karla <Karla Stoedter@nrc gov>; Kozak, Laura <Laura Kozak@nrc gov>; Hanna, Jolh n
<John Hanna@nrc gov>
Cc: Da ley, Robert <Robert Daley@nrc gov>; Robbins, John <John Robb jns@nrc gov>; Sargis, Daniel
<Daniel Sargis@nrc gov>
Subject:
Clinton Quest ions.docx
All ,
Please call if you have additional questions .
Thanks
Note to requester: Attachments are non-responsive records due to clarifying the request to exclude licensee originated documents.
From : Mitman Jeffrey To : Kozak Laura Cc : Kichline Michelle Subject : Clin ton - Containment Failure Date: Thursday, September 13, 2018 6:20:48 AM Attachments: PRA GG 01 001S01 RO.pd!
Revised-DRE-Grand-Gulf 3-23-17-mark-up.docx (b)(5)
Jeff Mitman
From: Mitman Jeffrey To : Kozak Laura Subject : Clin ton EDG Unavailabili ty SERP j t m.docm Date: Thursday, September 13, 2018 3 :15:01 PM Attachments: Clinton EDG Unavailability $ER P jtm .docm Laura, attached is a version showing my comments in Word revision marks. The comments are very limited. None are significant, that is feel free to accept or reject them.
Jeff Mitman
EXHIBIT 1 - IFRB FINDING FORM IFRB Cover Sheet Facility Name/Location: Name of Utility or Licensee:
Clinton Exelon Docket Number(s): EA Number: EA-18-104 50-461 (b)(5)
Issue Date:l(b)(5) Exh1-1 0609.0STP I
(b )(5) 5 Exh1 -2 0609.0STP Issue Date:1 (b-)(- )_ __.
(b)(5)
Issue Date: ~ Exh1-3 0609.05TP
(b )(5)
Issue Date: L] Exh1 -4 0609.0STP
(b)(5)
Issue Date: l (b)(5) I Exh1 -5 0609.0STP
(b)(5)
Issue Date: ~ Exh1 -6 0609.0STP
(b)(5)
Issue Date: ~ Exh1 -7 0609.0STP
(b )(5)
Issue Date: l(b)(5) I Exh1-8 0609.0STP
(b)(5)
Issue Date: ~ Exh1-9 0609.0STP
(b )(5)
Issue Date: l(b)(S) I Exh1-10 0609.0STP
{b)(5)
Issue Date: ~ Exh1-11 0609.0STP
(b )(5)
Issue Date: l(b)(S) Exh1-12 0609.0STP
(b)(5)
Issue Date: l(b)(5) I Exh1-13 0609.0STP
(b )(5)
Issue Date: ~ Exh1-14 0609.0STP
(b)(5)
Issue Date: l(b)(S) I Exh1-15 0609.05TP
(b )(5)
Issue Date:~ Exh1-16 0609.0STP
(b )(5)
Issue Date: l(b)(S) Exh1-17 0609.0STP
(b )(5)
Issue Date: l(b)(S) I Exh1-18 0609.0STP
(b )(5)
Issue Date: l(b)(5) Exh1-19 0609.0STP
Issue Date: ~ Att1-1 0609.05TP From: Mitman Jeffrey To : Kozak Laura Subject : Clinton lnop Both EDGs SD Pre SERP 09-13-18 (1).pptx Date: Thursday, September 13, 2018 7:57:12 AM Attachments: CHrilimJnop Both EDGs SD Pre SERP 09-13-18 11).opll<.
Laura, here is the presentation I'll be using .
I will not distribute the last slide but I will speak to it during the discussion.
Jeff
~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)
(b)(5)
Pre-Decisional U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Note to requester: This page was provided Cavity full End lowering Ito you
- in a previous rel, I cavity level
~ 6 inches below flange 13:54 RCS water level 09:43))begir lowering)) cavit\
level(
RPV Last bolt c Mode 5
tensioned0l:51 Mode 4 *
)
Div . 2 EOG "available"Div. 2 SX availableRCIC restorable (using Div. 1 DC Power) 02:30 iydroLPCS / SR Alt. SDCRHR/SDC A O0S02:24 I Div. 2 EDG operable 21:040
Div. 2 EOG opNSPS opDiv. 2
Div. 1 4Kv bus 1/S but AC 1/S & opDiv. 2 inop.Div. 1 EDG 01:30 HPCS Div. 2 AC Bus 1/S 17:25 I DC 1/S & op 08:00 End hydroRHR/SDC A 1/S 12:53 unavailableDiv. 1 DC unavailableLPCS (Div. 1) unavailableRHR / SDC A recoverable Iafter fill & vent} HPCS unavailable 00:30 Avai lable 5/9 5/ 2 5/16 11:18 5/18 00:0C 5/1'- 00:00 00:00 00: )0 00:00 II
* * --- * -- * -- * * * -- - --.!,/
5/11 I 5/13 I 5/15 5/17 OO:O~J 00:200RPV First) 00:00 23:28RHR/SDC B 00:00 00:00 Startine: ConditionsRH bolt tensioned( 1/SDiv. 2 Ed os:B0EF ii.Div.
z 1/SRHR/S':: A 00' . 2 DC OOSDiv. 2 SX navailal 15:040Div. 2 EDd I AT It I available 23:09RHR/SDC B "Operable"LPCI C & SRVs available I**
Actual relative risk level

=:r 4

Planned risk level (not to scale)
Version Date: 07-23-2018 l"r e-Becisior1al
(b)(5)
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Shutdown LOOP ET I Loss of Offsite Power - EMERGENCY POWER AC POWER RECOVERY # End State M4 LATE SUPPLY- (DIV I AND II) - 24 / 1 Hours (Phase - CD)
ISD-M4L-LOOP SD-EPS SD-AC-REC-24H 1 SD-M4L-LOOP-T >
0 I
0 0 0
I I
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- HI PRESSURE - , HEAT REMOVALUSING- ) "PROVIDE AlTERNA" CONTAINMENT E18ctii'C81 Conni"ction' Oiv. End State INJECTIONS (HCSICRD) I SUPPRESSION POOi. VENTING* SD 3100iv 2 (Phu* *CO)
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From: Mitman Jeffrey To : Kozak Laura Cc : ~
Subject : Clinton lnop. Both EDGs SD Pre SERP 09- 13-18 (1) .pptx Date: Thursday, September 13, 2018 10:35:36 AM Attachments: Clinton lnop Both EDGs SD Pre SERP 09 18 11} .pptx Laura, here are the final slides that were used (I did correct to typos that the meeting found) .
HQ would like to move forward with the SERP next week so that we can make the required due dates / milestones.
They want a list of known conservatisms and non-conservatisms. They also like to see sensitivities .
Jeff Mitman
~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)
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Cavity full End lowering cavity level
~ 6 inches below flange 13:54 RCS water level 09:43))begir lowering)) cavit\
level(
RPV Last bolt c Mode 5
tensioned0l:51 Mode 4 *
)
Div . 2 EOG "available"Div. 2 SX availableRCIC restorable (using Div. 1 DC Power) 02:30 iydroLPCS / SR Alt. SDCRHR/SDC A O0S02:24 I Div. 2 EDG operable 21:040
Div. 2 EOG opNSPS opDiv. 2
Div. 1 4Kv bus 1/S but AC 1/S & opDiv. 2 inop.Div. 1 EDG 01:30 HPCS Div. 2 AC Bus 1/S 17:25 I DC 1/S & op 08:00 End hydroRHR/SDC A 1/S 12:53 unavailableDiv. 1 DC unavailableLPCS (Div. 1) unavailableRHR / SDC A recoverable I after fill & vent} HPCS unavailable 00:30 Avai lable 5/9 5/ 2 5/16 11:18 5/18 00:0C 5/1'- 00:00 00:00 00: )0 00:00 II
* * --- * -- * -- * * * -- - --.!,/
5/11 I 5/13 I 5/15 5/17 OO:O~J 00:200RPV First) 00:00 23:28RHR/SDC B 00:00 00:00 Startine: ConditionsRH bolt tensioned( 1/SDiv. 2 Ed os:B0EF ii.Div.
z 1/SRHR/S':: A 00' . 2 DC OOSDiv. 2 SX navailal 15:040Div. 2 EDd I AT It I available 23:09RHR/SDC B "Operable"LPCI C & SRVs available I**
Actual relative risk level

=:r 4

Planned risk level (not to scale)
Version Date: 07-23-2018 3
(b)(5) 4 ~ U.S.NRC l,,1n,*rd ~.,,,._, Nu("fn~ llfs:0l11,,,7 C""""lP'ft" ProttttiNf Pt.op.Jr 1111d 1/N Envfronmo,t
(b)(5) 5 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 6 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Detailed Risk Assessment (DRE)
Approach (cont.)
Unavailability spans from cavity flooded to water at flange (Mode 5 - refueling) to head on and tensioned (Mode 4 - cold shutdown) including reactor pressure vessel (RPV) hydroMost of risk is expected to come from ~3,5 day period in cold shutdown when - DRE currently only evaluates this portion of outageDiv. 1 & 2 EDG were unavailableHPCS pump unavailable for most of period but was recoverableTime to boil (TTB) was about 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Time to core uncovery (TTCU) at low pressure approximately 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months sTime to core uncovery {TTCU) at high pressure approximately 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months sContributing risk factor: During this 3.5 day period, RPV let down to radwaste was in service via Div. 2 of residual heat removal (B RHR)lf LOOP occurs, B RHR pump will stop but let down will continue at a reduced flow rateThus if letdown is not secured, loss of inventory (LOI) event occursBecause cues are clear and procedures are precise, risk contribution is expected to be low and therefore ignored 7 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 8 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~ n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
en (b)(5) 10 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 11 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 12 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 13 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Shutdown LOOP ET I Loss of Offsite Power - EMERGENCY POWER AC POWER RECOVERY # End State M4 LATE SUPPLY- (DIV I AND II) - 24 / 1 Hours (Phase - CD)
ISD-M4L-LOOP SD-EPS SD-AC-REC-24H 1 SD-M4L-LOOP-T >
0 I
0 0 0
I I
2 I
I SD-M4L-LOOP-T >
0 I 0 I 3
I SD-M4L-LOOP-T >i 14 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Shutdown LOOP ET {cont.)
- HI PRESSURE - , HEAT REMOVALUSING- ) "PROVIDE AlTERNA" CONTAINMENT E18ctii'C81 Conni"ction' Oiv. End State INJECTIONS (HCSICRD) I SUPPRESSION POOi. VENTING* SD 3100iv 2 (Phu* *CO)
. - - *<. .>---*O--~=-~~c ~===-*~c:====-*Oo- --o---c~--0----0--I
<DUMMY-FT> SD-SOC S0-HPI SO-ALT-HEAT Sl)..CVS El.ECJ<TIE 1 I OK I 7
o---[
o-L C-EXT (J-- - I OK
..----c; , - - - ~ o----o--1 o---1s 9 OK OK II SD-SPC*EXT v----L o----Co---1 o---1 10 11 OK CO-SO I
I e-exr u....----0----0--I ,2 OK I o-L~ ~ SD-SPC-0 o----Co---1 o---1 o---1,.
0---l 's 13 1&
OK OK OK co-so I
1 1
I o---1 L--- } - - - -C> - - - - -1..
o----Co---1 17 18 I OK CO-SO II e-exr u - - -1 o---1 I 1 9 OK I o-L~v----L SD-SPC-o----o--1 o----Co---1 o---1 o---1 20
~=II 21 22 23 OK OK OK CO-SO I
I o---1 24 OK I o----Co---1 26 co-so 1
15 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
I.(')
.0
(b)(5) 17 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 19 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
From: Kozak Laura To : Louden Patrick: Stoedter Karla Cc : Lara Julio: Hanna John : Sanchez Santiago Elba: Sargis Daniel Subject : Clinton SOP Date: Thursday, September 13, 2018 10:44:30 AM Attachments: Clinton lnop Both EDGs SD Pre $ERP 09-13-18 11} 1003).pptx FYI Jeff briefed NRR management today. His presentation is attached.
Laura
~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)
(b)(5) 2 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Cavity fu ll End lowering cavity level
~ 6 inches below fla nge 13:54 RCS wat er level 09:43))begir lowering)) cavit\
level(
RPV Last bolt c M ode 5
tensioned0l :51 Mode 4 *
)
Div . 2 EOG "available"Div. 2 SX availableRCIC restorable (using Div. 1 DC Power) 02:30 iydroLPCS / SR Alt. SDCRHR/SDC A O0S02:24 I Div. 2 EDG op erable 21:040
Div. 2 EOG opNSPS opDiv . 2
Div. 1 4Kv bus 1/S but AC 1/S & opDiv. 2 inop.Div. 1 EDG 01:30 HPCS Div . 2 AC Bus 1/S 17:25 I DC 1/S & op 08:00 End hydroRHR/SDC A 1/S 12:53 unavailableDiv. 1 DC unavailableLPCS (Div. 1) unavailableRHR / SDC A recoverable I after fill & vent} HPCS unavailable 00:30 Avai lable 5/16 5/18 II 5/9 5/ 2 11:18 5/1'- 00:00 00:00 00: )0 00:00
oooc - - -
* --- * -- * -- * * * -- __ _!,/
5/11 I 5/13 I 5/15 5/17 OO:O~J 00:200RPV First) 00 :00 23:28RHR/SDC B 00:00 00:00 Startine: ConditionsRH bolt tensioned( 1/SDiv. 2 Ed os:B0EF ii.Div.
z 1/SRHR/S ':: A 00' . 2 DC OOSDiv. 2 SX navailal 15:040Div. 2 EDd I AT It I available 23:09RHR/SDC B "Op erable"LPCI C & SRVs available I**
Act ual relative risk level

=:r 4

Planned risk level (not to scale)
Version Dat e: 07-23-2018 3
(b)(5) 4 ~ U.S.NRC l,,1n,*rd ~.,,,._, Nu("fn~ llfs:0l11,,,7 C""""lP'ft" ProttttiNf Pt.op.Jr 1111d 1/N Envfronmo,t
(b)(5) 5 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 6 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
r--
(b)(5) 8 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~ n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 9 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 10 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 11 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 12 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
(b)(5) 13 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Shutdown LOOP ET I Loss of Offsite Power - EMERGENCY POWER AC POWER RECOVERY # End State M4 LATE SUPPLY- (DIV I AND II) - 24 / 1 Hours (Phase - CD)
ISD-M4L-LOOP SD-EPS SD-AC-REC-24H 1 SD-M4L-LOOP-T >
0 I
0 0 0
I I
2 I
I SD-M4L-LOOP-T >
0 I 0 I 3
I SD-M4L-LOOP-T >i 14 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""""u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Shutdown LOOP ET {cont.)
- HI PRESSURE - , HEAT REMOVALUSING- ) "PROVIDE AlTERNA" CONTAINMENT E18ctii'C81 Conni"ction' Oiv. End State INJECTIONS (HCSICRD) I SUPPRESSION POOi. VENTING* SD 3100iv 2 (Phu* *CO)
. - - *<. .>---*O--~=-~~c ~===-*~c:====-*Oo- --o---c~--0----0--I
<DUMMY-FT> SD-SOC S0-HPI SO-ALT-HEAT Sl)..CVS El.ECJ<TIE 1 I OK I 7
o---[
o-L C-EXT (J-- - I OK
..----c; , - - - ~ o----o--1 o---1s 9 OK OK II SD-SPC*EXT v----L o----Co---1 o---1 10 11 OK CO-SO I
I e-exr u....----0----0--I ,2 OK I o-L~ ~ SD-SPC-0 o----Co---1 o---1 o---1,.
0---l 's 13 1&
OK OK OK co-so I
1 1
I o---1 L--- } - - - -C> - - - - -1..
o----Co---1 17 18 I OK CO-SO II e-exr u - - -1 o---1 I 1 9 OK I o-L~v----L SD-SPC-o----o--1 o----Co---1 o---1 o---1 20
~=II 21 22 23 OK OK OK CO-SO I
I o---1 24 OK I o----Co---1 26 co-so 1
15 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
L t')
.0 I'-" _J
(b)(5) 19 U.S.NRC l,,1n,o*,d ~orr-, Nu(:fn~ R*s:0l11.,,7 C""" "u*11~n ProttttiNf Pt.op.fr and 1/N Envfron,n.o1t
Note to requester: Attachment is a non-responsive record due to clarifying the request to exclude licensee originated documents.
From: Kozak Laura To: Mitman Jeffrey Subject : Fw: Procedures changes as a result of SDP eval for DG Date: Wednesday, November 28, 2018 11 :02:34 AM Attachments: AR 4198001.pdf From: Sa nchez Santiago, Elba Se nt: Wednesday, November 28, 2018 10:58 AM To: Kozak, Laura
Subject:
Procedures changes as a result of SDP eval for DG Laura, (b)(5)
Just wanted to share this with you for FYI purposes. Let me know if you have any questions.
Thanks, Elba From: el ba .sa nchezsantiago@nre.gov [ma ilto :el ba .sanch ezsa ntiago@nre.gov]
Sent: Friday, November 30, 2018 5:46 AM To: Sanchez Santiago, Elba <Elba.SanchezSantiago@nrc.gov>
Subject :

ML20197A084

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