ML20197A085
| ML20197A085 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/2020 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML20197A080 | List: |
| References | |
| FOIA, NRC-2019-000253 | |
| Download: ML20197A085 (929) | |
Text
From: Kozak Laura To: Norton Charles Subject : Re: Clinton regulatory conference - Friday Date: Wednesday, November 28, 2018 2:57:40 PM Thanks ! I'm on a cal l. Lets ta lk tomorrow From: Norton, Charles Se nt: Wednesday, November 28, 2018 2:33 PM To: Koza k, Laura
Subject:
RE: Clinton regulatory conference - Friday I sent the message below before I was ready. We can talk with you before 3 pm today or any time you call tomorrow.
Chuck From: Norton, Charles Sent: Wednesday, November 28, 2018 2:31 PM To: Koza k, Laura <Laura.Kozak@ nrc.gov>
Subject:
RE: Clinton regulatory conference - Friday Jim and I went over the Clinton oresentation toaether. We have some thouahts to share with you. l(b)(S) I (b )(5)
From: Kozak, Laura Sent: Wednesday, November 28, 2018 10:59 AM To: Norton, Charles <Charles Norton@nrc.gov>
Subject:
Clinton regulatory conference - Friday Chuck I am delayed in looking at your issue because of the regulatory conference on Friday. Can I get back with you guys next week?
Also, I attached the Clinton presentation,. I would like to talk to you about it, given your Operator background and Fukushima background. Wou ld you have time to take a look at it and talk with me later today or tomorrow?
Laura
From: Kozak Laura To : west Steven : Roberts Darrell : Giessner Jack : .E.LJ.; Lara Julio: O"Brjen Kenneth : Shuaibi Mohammed ; file.meL.
Kenneth ; Stoedter Karla: Cameron Jamnes ; Franovich Mike ; .Eo.o.g,._C,!; Mitman Jeffrey ; Phillips Charles :
Sanchez Santiago, Elba; Sargis, Daniel Subject : Clinton regulatory conference Note to requester: The attachment to this Date: Thursday, November 29, 2018 3:48:13 PM email has been redacted in its entirety under Attachments : Clinton Reoulatory Conference SRA notes jtm docx FOIA Ex. B5 (deliberative process privilege).
Jeff and I put together the attached one-page document.
The document covers what we think is new information , what we think are areas of disagreement but is not new information , and some important points to keep in mind during tomorrow's meeting.
If anyone has any questions before the conference, we will both be available . Please share this document as necessary with others for information.
Laura
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Note to requester: The attachment to this email has been redacted in its From: Kozak Laura entirety under FO IA Ex. B5 To : Mitman Jeffrey (deliberative process Subject : FW: Clinton Regulatory Conference SRA notes jtm.docx privilege).
Date: Thursday, November 29 , 2018 1 :04:00 PM Attachments: Cli!l1lfilBeguJato_ry~rence SRA notes j~cx.
From: Kozak, Laura Sent: Thursday, November 29, 2018 12 :35 PM To: M itman, Jeffrey <Jeffrey. M itman@ nrc .gov>
Subject:
RE : Clinton Regulatory Conference SRA notes jtm .docx Slightly revised From: Mitman, Jeffrey Sent: Thursday, November 29, 2018 9:34 AM To: Kozak, La ura <Laura.Kozak@nrc.gov>
Subject:
Clinton Regulatory Conference SRA notes jtm.docx
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From : Kozak Laura To : west Steven : Roberts Darrell : Giessner John : Louden Patrick: Lara Julio : O"Brjen Kenneth : ~
Mohammed: Franovich Mike : .Eo.!:!.g,.J;,!; Stoedter Karla : Cameron Jamnes: Riemer Kenneth : Phillips Charles :
Sanchez Santiago, Elba; Sargis, Daniel: Mitman. Jeffrey: Zoulis, Antonios : Casey, Lauren Subject : FW: Comments on Exelon presentation Date: Friday, November 30, 2018 8 :12:00 AM Attachments : cps Piv 2 PG Rea cont Presentation 111-1 s-1s}/2a1 odf All Jeff marked up the licensee procedure with some comments and highlighted areas of new information and points of disagreement.
See attached.
Note to requester: The attachment to this email has been withheld in its Laura entirety under FO IA Ex. B5 (deliberative process privilege).
From: Mitman, Jeffrey Sent: Thursday, Novembe r 29, 2018 7:46 PM To: Kozak, La ura <Laura.Kozak@ nrc.gov>
Cc: M itma n, Jeffrey <Jeffrey. M it ma n@nrc.gov>; Zouli s, Antonios <Anto nios .Zo ulis@nrc.gov>
Subject:
Comments on Exelo n prese ntatio n
- Laura, As promised .
Jeff Mitman
From: Kozak Laura To : Mitman Jeffrey Subject : one pager Date: Thursday, November 29, 2018 11 :23 :00 AM Attachments: Cli!l1lfilBeguJato_ry~rence SRA notes j~cx.
Note to requester: The attachment to this email has been withheld in its entirety under FOIA Ex. B5 (deliberative process privilege) .
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Note to requester: The attachment to From: Kozak Laura this email has been withheld in its To : Mitman Jeffrey entirety under FO IA Ex. B5 Subject : RE: Clinton Regulatory Conference SRA not es jtm .docx (deliberative process privilege).
Date: Thursday, November 29 , 2018 12:35 :00 PM Attachments: Cli!l1lfilBeguJato_ry~rence SRA notes j ~ c x.
Slightly revised From: Mitman, Jeffrey Sent: Thursday, Novem ber 29, 20 18 9:34 AM To: Ko zak, Lau ra <Laura .Kozak@ nrc.gov>
Subject:
Clinton Regul atory Co nference SRA notes j tm. do cx
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Note to requester: The attachments to this From : Kozak Laura email have been withheld in their entirety To : Rodriquez Lionel under FO IA Ex. B5 (deliberative process Subject : regulatory conference privilege).
Date: Friday, November 30 , 2018 11:44:00 AM Attachments: Clinton ReguJator'lJ&nt~RA_nQ!es jtrMI~
CPS Div 2 DG Reg Cont Presentation / 11-19-18)(2al.pdf Internal information only
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Note to requester: The attachment to this email has been withheld in its entirety under FO IA Ex. B5 (deliberative process privilege).
From: Sanchez Santiago Elba To : Kozak Laura Cc : Mitman Jeffrey Subject : Clinton Regulatory Conference Notes.docx Date: Monday, December 03, 2018 1:58:00 PM Attachments: Clinton Regulatory Conference Notes.docx
- Laura, Attached are the notes I took during the Clinton reg conference. I know for a fact that there are at least 2 things missing. Mike Franovich and Jeff Mitman each requested someth ing be addressed in the white paper, and I can't find those items in my notes.
Hope this helps.
- Thanks, Elba
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Note to requester: The attachment to this email has been withheld in its entirety under FO IA Ex. B5 From: Kozak Laura (deliberative process privilege).
To : Mitman Jeffrey : Sanchez Santiago Elba Subject : regulatory conference information Date: Monday, Dece mber 03 , 2018 3:34 :00 PM Attachments: Cli!l1lfilBeguJato_ry~rence Notes.docx_
I changed Elba's list a bit and rearranged into two sections 1) new information and 2) questions not necessarily related to new information .
Please provide any changes/additions. We'd like to get the list to the licensee tomorrow.
Jeff, I'd like you to be on the phone with me. I think Julio would also like to attend the call.
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From : Kozak Laura To : Mitman Jeffrey : Sanchez Santiago Elba Subject : Clinton discussion today Date: Tuesday, December 04 , 2018 7 :23:00 AM Attachments: Cli!l1lfilBeguJato_ry~rence Notes r~ .
I cleaned the document up a bit - see attached for today's discussion .
I plan to run through the list - Jeff, yo u chime in as necessary.
Laura
Clinton Regulatory Conference Notes (b)(5)
Note to requester: Attachment is a non-responsive record due From: Kozak Laura to clarifying the request to To : Mitman Jeffrey exclude licensee originated Subject : FW: CC-GL-118-1003.pdf Date: Tuesday, December 04, 2018 3:39:00 PM Attachments: CC-CL-118-1003.pdf FYI From: Sanchez Sant iago, El ba Sent: Tuesday, Decem ber 04, 20 18 2:42 PM To: Ko zak, Lau ra <Laura .Kozak@ nrc.gov>
Cc: Phi lli ps, Charles <Ch arl es .Phill ips@nrc.gov>
Subject:
CC-CL-118-1003.pdf
- Laura, Attached is the Clinton FLEX implementation plan. The portion I was discussing with you is on page 24 and I highlighted the pertinent sections .
-Elba
Note to requester: The attachment to this email has been withheld in its entirety under FOIA Ex. 85 (deliberative process privilege).
From: Phillips Charles To : Biemer Kenneth Cc : Kozak Laura: Sanchez Santiago Elba: st Peters Courtney Subject : Reg Conference mtg Summary draft Date: Tuesday, December 11, 2018 9:38 :22 AM Attachments: Rea Conference mto Summary draft 1 .docx Here is my draft. I th ink everything is here. It you want more detail let me know.
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Note to requester: The attachment to this email has been withheld in its entirety under FO IA Ex. B5 (deliberative process privilege).
From: Phillips Charles To : Biemer Kenneth Cc : Kozak Laura : Sanchez Santiago Elba Subject : Reg Conference mtg Su mmary draft 3 Date: Tuesday, December 11, 2018 3 :34 :01 PM Attachments: Rea Conference mto Summary draft 3.docx I added (or subtracted) all the comments to this draft.
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From: Kozak Laura To: Biemer Kenneth: Sanchez Santiago Elba: Mitman Jeffrey : Lara Julio Subject : Re: RS-18-146 Exelon Evaluation of Preliminary White Finding Date: Saturday, December 15, 2018 4:18:13 PM Ken I believe we need to respond in writing to this letter, only to address the later paragraph that names Jeff and me and characterizes the attachment as response to our questions, which it is not. Maybe a thank you letter that puts the information in the proper context. Our "questions" were seeking to understand the factual "new" information that Exelon had.
Remember, we are seeking the "new information" that the licensee was supposed to put o n the docket prior to the regulatory conference which they did not. We were in a very awkward position by having to identify what was new and ask the licensee for it. Our mistake from not insisting o n this back when the presentation was sent in.\
Laura From: Riemer, Kenneth Sent: Friday, December 14, 2018 3:27:44 PM To: Sanchez Sant iago, Elba; Kozak, Lau ra; M itman, Jeffrey
Subject:
RE: RS-18-146 Exelon Evaluation of Prelimina ry White Finding From: Sa nchez Santiago, Elba Sent: Friday, December 14, 2018 2:37 PM To: Riemer, Kenneth <Kenneth.Riemer@n rc.gov>; Kozak, Laura <Laura.Koza k@nrc.gov>; M itman, Jeffrey <Jeffrey.M itman@nrc.gov>
Subject:
FW: RS-18-146 Exelon Evaluation of Prelim inary Wh ite Find ing Attached is the licensee's white paper and their response to our post reg conference questions. As the title of the document indicates, th is document contains only attachments 1 and 2. The bulk of the information related to our questions are in attachments 3 - 15.
Those attachments total over 2000 pages and will be sent in the form of a disc to Laura and Jeff. They will also be sent as hardcopies to the R3 RA office and document control desk in HQ.
From: Gaynor, El len M:(GenCo-Nuc) [majlto*Ellen Gaynor@exeloncorp com]
Sent: Friday, December 14, 2018 2:15 PM Cc: ken evaos@il lioois gov: jason fields@illioois gov; steveo reynolds@ illioois gov: Sanchez Sa nt iago, Elba <Elba SanchezSantjago@nrc.gov>
Subject:
[External_Sender] RS-18-146 Exelon Eva luation of Prelim inary White Fi ndi ng Thank you!
Have a great weekend.
Ellen Gaynor OSS - Licensing 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 enor, 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: Lara Julio To: Biemer Kenneth: Kozak Laura Cc: Louden Patrick
Subject:
Clinton internal comms Date: Monday, December 17, 2018 11:51 :54 AM Attachments: jmaqe002.png Ken, I think we should be more proactive in internal comms with respect to the Clinton Prelim-White finding . Such comms would help all internal stakeholders appreciate the pending actions, schedules, and our view of the information submitted by Exelon. This will help Steve/Darrell/Jack as well when communicating with NRR, and OEDO. We should be able to get something out by tomorrow.
Please keep jeff and laura informed as this summary is developed.
Something like:
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Julio Lara, P.E.
Deputy Director Division of Reactor Projects, RIii 630-829-9601
~ Fo * ;n * "" ofi 9' Empow ri11g 11,e tri11i11 for l' t'lle11 e
From: Kunowskj Michael To: ALL.Ba Cc: cook Christopher
Subject:
Daily Meeting Notes Monday December 17 Date: Monday, Decemb er 17, 2018 9:15:53 AM The Daily Morning Meeting News for Monday, December 17, 2018 Regional Duty Officer: Mike Kunowski; incoming, Ann Marie Teleconference Number: (800) 779-9565; Passcode: I I .. - - - - -....... (b)(6)
Note: This newsletter may contain pre-decisional info. Do not distribute outside the NRC.
Highlight of the week/Leadership Model: Receptivity to New Ideas & Thinking Support Issues:
RA: Steve is in the office on Tuesday and Wednesday; 11 :30 tomorrow, pizza farewell for him; Entergy drop-in tomorrow to talk in generalities about Palisades DRP:
DRS:
DNMS:
DRMA: executive leadership training tomorrow for team leads and above EICS: ARB today and a modified panel for a materials case this week 5
STATES: ... rb-)(- )_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __.
PAO: r )(S)
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oldest commercial plant in the country at 49 years old; and Bulletin of Atomic Scientists had an article on radwaste. See NRG in the News Today Materials Events/Issues:
Reactor Events:
Plant Status BRANCH 1 (Ken Riemer)
Clinton: 2000-page response received Friday on the two EOG OOS issue. After the staff has reviewed it, an internal caucus will be held to determine if it changes the
proposed escalated enforcement.
Dresden:
U2:
U3:
LaSalle:
U1:
U2:
Quad Cities:
U1:
U2:
BRANCH 2 (Darius Szwarc) 5 Davis-Besse: ._l(b_)_( _) _ _ _ _ _ _ _ _ _ _ _ _____.
Duane Arnold:
5 rb-)(_ _) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___,
Palisades: ...
Perry:
BRANCH 3 (Pete Peterson)
Braidwood:
Byron:
Monticello:
Prairie Island:
Ul:
BRANCH 4 (Eric Duncan)
DC Cook:
Fermi: l<b)(5)
!(b)(5)
Point Beach :
U1: . - - - - - - - - - - - - - - - - - - - - - - - - - - - -
U2 : l(b)(5) I 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 : Kozak Laura: Phillips Charles Subject : Proposed Clinton Comm Plan Date: Monday, December 17, 20 18 3:00:28 PM Attachments: Communication Plan.Clinton.docx See attached - feel free to change as necessary
Communication Plan Clinton preliminary White EDG Finding and Violation (b)(5)
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From: Kozak Laura To: Lara Julio: Biemer Kenneth Cc: Louden Patrick
Subject:
RE: Clinton internal comms Date: Monday, December 17, 2018 12:39:24 PM Attachments: imaqe001.png I'd like to see the communication before it goes out.
From my perspective, the NRG performed a comprehensive preliminary significance determination that involved significant interactions with the licensee and appropriately considered many of the licensee's positions presented at the regulatory conference. We knew at the preliminary SERP and going into the conference that the licensee disagreed with our evaluation and many of the assumptions. We were/are open to new technical and risk information to consider, but I hope we do not revisit known areas of disagreement for which there is no new information.
It was the licensee's obligation to provide the technical and risk information on the docket prior to the regulatory conference, which they did not do. Now we have received information - some of which is new, but most of it is not. However, we will need to go through it to determine what is new.
As a reminder below I have pasted an excerpt from the SERP package where we summarized the licensee's disagreements. We have discussed these at length internally.
The licensee performed an evaluation of the findi ng and concluded that the risk significance of the finding was of very low safety significance (approximately E-8).
In compa ring t he licensee eva luation to the NRC detai led risk evaluation the following differences were noted:
Diesel Generator 2 recovery- The licensee's HEP for failing to recovery the diesel generator was 4.6E-3. This HEP is very optim istic compared to the NRC HEP and is approximately a factor of 200 less than t he data/st atistica lly based va lue. The licensee evaluat ion concludes that human er ror is dominated by execut ion. Diagnosis of t he condition was viewed as obvious and virtually certain to occur. The cu rrent NRC view is t hat diagnosis is t he dom inant error mode, but that diagnosis and execution of recovery actions has a high likelihood of success.
The licensee's evaluation used a red uced LOOP frequency. Switchyard LOOPs were removed from the estimat e based on the licensee's judgment that t he switchya rd was protected.
The licensee developed an event t ree sim ilar to t he phase 2 event tree and est imated branch fail ure probabilities.
The licensee's estimat es for FLEX and cross-tie fail ure are not subst antially different from the NRC's, but are slight ly more opti mistic.
In general, the licensee stated that there would be high assurance of the recovery of AC power because of t he late sh utdown condition with extra t ime to core damage and extra staffing d ue to the outage. The licensee stated that t he efforts for recovery, FLEX, and the cross-tie wou ld be performed in parallel, due to the staffi ng From: Lara, Julio Sent: Monday, December 17,. 2018 11:52 AM To: Riemer, Kenneth <Kenneth.Riemer@n rc.gov>; Kozak, Laura <Laura.Koza k@nrc.gov>
Cc: Louden, Patrick <Patrick.Louden@ nrc.gov>
Subject:
Clinton internal com ms Ken, I think we should be more proactive in internal comms with respect to the Clinton Prelim-White finding. Such comms would help all internal stakeholders appreciate the pending actions, schedules, and our view of the information submitted by Exelon. This will help Steve/Darrell/Jack as well when communicating with NRR, and OEDO. We should be able to get something out by tomorrow.
Please keep jeff and laura informed as this summary is developed.
Something like:
(b )(5)
(b)(5)
Julio Lara, P.E.
Deputy Director Division of Reactor Projects, RIii 630-829-9601
From : Kozak Laura To : Riemer Kenneth : Phillips Charles Cc : Cameron Jamnes Subject : RE: Proposed Clinton Comm Plan Date: Monday, December 17, 20 18 3:41 :00 PM Attachments: Communication Plan .Clinton LCK.docx Here are my suggested changes.
Separately- I shared with Julio my view that we should not be calling Exelon . We've had many opportunities to communicate with the licensee what appropriate interaction looks like , including at the regulatory conference, and we did not take them. Too late now, let's just move forward with the review.
From: Riemer, Ke nn eth Sent: M onday, December 17, 2018 3:00 PM To: Koza k, La ura <Laura.Kozak@ nrc.gov>; Phi llips, Ch arles <Charles. Phillips@nrc.gov>
Subject:
Proposed Clinton Comm Pla n See attached - feel free to change as necessary
Communication Plan Clinton preliminary White EDG Finding and Violation (b )(5)
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From: Kozak Laura To: Cameron Jamnes: Riemer Kenneth Subject : RE: response to Exelon Date: Monday, December 17, 2018 2:09:25 PM Attachments: Clinton Regulatorv Conference information reauest.docx.
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From: Cameron, Jamnes Sent: Monday, December 17, 20181:57 PM To: Riemer, Kenneth <Kenneth.Riemer@nrc.gov>; Kozak, Lau ra <Laura.Kozak@nrc.gov>
Subject:
Re: response to Exelon (b)(5)
From: Riemer, Kenneth Se nt: Monday, December 17,. 2018 10:54:32 AM To: Kozak, Laura; Cameron, Jam nes
Subject:
RE: response to Exelon (b)(5)
From: Kozak, Laura
Sent: M onday, December 17, 2018 8:55 AM To: Riemer, Kennet h <Kenneth.Riemer@nrc.gov>; Came ron, Jamnes <Jamnes.Cameron@nrc.gov>
Subject:
response to Exelon See attached for some input to a response letter.
Clinton Regulatory Conference Notes New information: 5 areas of new information to be considered.
Battery Life
- Battery life extension evaluation to support 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> battery life Recovery of the DG
- Copy of training material referenced in slide 9 "Assumption 13"
- Copy of the completed questionnaires sent to the 28 SROs as referenced in slide 18 Copy of the completed surveys provided to the six CPS shift managers referenced on slide 18
- Copy of time validation described in slide 19
- Copy of procedure(s) and training (including shutdown simulator exercises) that would direct closure of the shutdown cooling valve§. as referenced in slide 10
- Copy of HEP analysis for operator action to close the shutdown cooling valves referenced in slide 45 Pressure Control
- Copy of procedures and training (including shutdown simulator exercises) to support maintaining RPV pressure below 100 psig without low pressure injection as discussed on slide 45.
Division 3 Cross-tie
- Copy of time validations for evolutions described in slides 10 (cross-tie)
Questions (not necessarily related to new information):
- Any additional shutdown SBO training? If so provide training materials.
- Would the control room annunciators be impacted by the DC load shed?
- Any additional FLEX or cross-tie training materials to provide?
- What was the water level in the reactor vessel during the timeframe when both Division 1 and Division 2 diesels were unavailable?
- Exelon indicated that the credit we were giving re FLEX was inconsistent with the NRC FLEX SER. Please supplies details.
From:
To : Milman teffrev Subject : Clinton
Jeff Laura
- 28 SROs from other stations (including non-Exelon) were given CPS procedures and scenarios that recreated the postulated scenario
- All SROs stated that they remain in the LOOP procedure and NOT enter ELAP
From : Kozak Laura To : Riemer Kenneth Subject : Clinton Date: Wednesday, December 19, 2018 11:43 :00 AM Attachments: Co mmunication Plan.Clinton LCK.docx I made some significant changes - see attached .
Communication Plan Clinton preliminary White EDG Finding and Violation (b )(5)
(b)(5)
From: Lara Julio To : west Steven : Roberts Darrell : Giessner Jack Cc : Shuaibi Mohammed: O"Brjen Kenneth ; ru Subject : Clin ton Prelim White finding - Status Update Date: Wednesday, December 19, 2018 1:25 :10 PM Attachments: Clinton PrelimWhite CommPlan.docx imaaeoo3 ona FYI.
Later today we will forwarding the attached status update on Clinton to internal stakeholders.
Julio Lara, P.E.
Deputy Director Division of Reactor Projects, RIii 630-829-9601 logo-emails-1
December 19, 2018 Communication Plan Clinton preliminary White EDG Finding and Violation (b)(5)
(b)(5)
From: Cameron Jamnes To : Lambert Kenneth Cc : Lara Julio: Shuaibi Mohammed Subject : Re : EA- 18-104 ; Clinton Date: Wednesday, December 19, 2018 12:06:46 PM Thanks Ken!
Original Message --------
From: "Lambert, Kenneth" <Kenneth.Lambert@nrc.gov>
Date: Wed, December 19, 2018 10:15 AM -0600 To: "Cameron, Jamnes" <Jamnes.Cameron@nrc.gov>
Subject:
EA-18-104; Clinton Jamnes, (b)(5)
Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission 630-810-4376 kenneth .lambert@nrc.gov
From: Kozak Laura To: Aird David: Garmoe Alex: Zouljs Antonjos Cc: Helton Donald
Subject:
FW: Clinton Prelim White finding - Status Update Date: Wednesday, December 19, 2018 4:16:00 PM Attachments: Clinton PrelimWhite CommPlan.docx 1maoeoo3 ono FYI. Let me know if you have any questions.
From: Lara, Julio Sent: Wednesday, December 19, 2018 4: 11 PM To: Franovich, M ike <Mike.Franovich@ nrc.gov>; M iller, Chris <Chris.Miller@nrc.gov>; Fong, CJ
<CJ .Fong@ nrc.gov>; Groom, Jeremy <Jeremy.Groom@nrc.gov>; Dickson, Billy
<Billy.Dickson@nrc.gov>; Felt s, Russell <Russel l. Felts@nrc.gov>; M itman, Jeffrey
<Jeffrey. M itman@nrc.gov>
Cc: Louden, Patrick <Patrick. Louden@nrc.gov>; Riemer, Kenneth <Ken neth.Riemer@nrc.gov>;
Kozak, La ura <Laura.Kozak@ nrc.gov>; Jamnes Cameron <hi ronori. pet erson>
Subject:
Clinton Prelim White finding - Status Update Update status and comm plan for Clinton prelim White finding.
Please forward to other internal stakeholders as appropriate.
Thanks julio Julio Lara, P.E.
Deputy Director Division of Reactor Projects, RIii 630-829-9601 0- F°'" ;,., ,,. Su/<1y
£mpott'cri11g Others Stri1*it1J: for £xccllc1tu
December 19, 2018 Communication Plan Clinton preliminary White EDG Finding and Violation (b )(5)
(b )(5)
From: Kozak Laura To: fQng._Q,!
Cc: Mitman Jeffrey
Subject:
RE: 255 day deadline Date: Wednesday, December 19, 2018 11:18:00 AM (b )(5)
Laura From: Fong, CJ Sent: Wednesday, December 19, 2018 11:15 AM To: M itma n, Jeffrey <Jeffrey. M itma n@nrc.gov>
Cc: Koza k, La ura <Laura.Kozak@ nrc.gov>
Subject:
255 day dead line Thanks,
{!fl 7fJl19, P. &.
Chief, PRA Oversight Branch (APOB)
Division of Risk Assessment Office of Nuclear Reactor Regulation (30 1) 415- 8474
From:
To:
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From: Kozak, Laura Sent: Wednesday, December 19, 2018 10:19 AM To: Glessner, John <John.Glessner@nrc.gov>
Subject:
Chnton - declaration of HAP (b )(5)
From: Mitman Jeffrey To: Lara Julio Cc: Kozak Laura: ~
Subject:
RE: Clinton Prelim White f inding - Status Update Date: Wednesday, December 19, 2018 4:25:02 PM Attachments : Clinton PrelimWhite CommPlan itm docx imaoeoo1 coo Julio, thanks for the write-up. I've made a few suggested changes to it for your consideration.
Jeff Mitman From: Lara, Julio Se nt: Wednesday, December 19, 2018 5:11 PM To: Franovich, Mike <Mike.Franovich@ nrc.gov>; Miller, Chris <Chris.Miller@nrc.gov>; Fong, CJ
<CJ.Fong@ nrc.gov>; Groom, Jeremy <Jeremy.Groom@nrc.gov>; Dickson, Billy
<Billy.Dickson@nrc.gov>; Felts, Russell <Russel l. Felts@nrc.gov>; Mitman, Jeffrey
<Jeffrey.M itman@nrc.gov>
Cc: Louden, Patrick <Patrick.Louden@nrc.gov>; Riemer, Kenneth <Ken neth.Riemer@nrc.gov>;
Kozak, La ura <Laura.Kozak@nrc.gov>; Jamnes Cameron <hironori.peterson>
Subject:
Clinton Prelim White finding - Status Update Update status and comm plan for Clinton prelim White finding.
Please forward to other internal stakeholders as appropriate.
Thanks julio Julio Lara, P.E.
Deputy Director Division of Reactor Projects, RIii 630-829-9601 0- Foe" ;,., on Sa/tlJ*
Empowtrittg Others Strfrittg for £xulle1tu
December 19, 2018 Communication Plan Clinton preliminary White EDG Finding and Violation (b)(5)
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Note to requester: The second attachment to this email has been withheld in its entirety under FOIA From: Stoedter Karla Ex. B5 deliberative recess rivile e .
To : Riemer Kenneth Subject : Time line of Events for Preliminary Wh ite Find ing .docx Date: Wednesday, December 19, 2018 3:30 :18 PM Attachments: Iirr!eline of Events fou'relimin~rv Wh ite.floding .~
Clinton EOG Unavailability IFRB rev2.docm
- Ken, Here is the timeline. It doesn't include the planning SERP which Laura likely has the date for.
The IFRB package with the 255 date is on the G drive, branch 1, Clinton , 2018 EOG inoperability during outage. I attached it so you wouldn't have to find it.
Karla
90-Day Clock Timeline for Clinton Power Station Division 2 EDG Preliminary White Finding Date Event 05/17/2018 Clinton Power Station discovers the Division 2 EDG was inoperable while the Division 1 EDG was out of service for planned maintenance placing the unit in a shutdown risk yellow condition due to electrical power unavailability.
05/25/2018 Region 3 completes MD 8.3 evaluation and concludes a Special Inspection is warranted.
05/29/2018 Region 3 management decides to launch SIT in late June to allow licensee to focus on reactor restart activities, complete corrective actions, and to support the completion of a previously scheduled 95001 inspection.
06/25-29/2018 Region 3 conducts Special Inspection at Clinton to review cause of EOG inoperability and licensee corrective actions. The inspectors identify that a failure to follow multiple procedures led to the Division 2 EDG being incorrectly restored to service on May 11 ,
2018. A senior reactor analyst from Region 3 and a risk analyst from HQ t raveled to the site to support the team during the inspection.
The inspectors hold exit meeting to discuss the above finding and two other findings.
07/19/2018 IFRB agrees with proposed performance deficiency regarding the failure to follow multiple procedures and the need to perform a detailed risk evaluation.
08/03/2018 Re-exit completed with the licensee. 120 Day Upfront Metric Met.
08/23/2018 Special Inspection Report is issued including a finding with a TBD significance and a corresponding apparent violation of 10 CFR 50, Appendix B, Criterion V and TS 3.8.2.
NRR/DRA performs detailed risk evaluation with regional SRA support including a review of the licensee's 500+ page risk evaluation.
90 Day ROP Clock Starts 09/11/2018 Region 3 risk analyst and HQ risk analyst travel to Clinton Station to explain our risk model to the licensee's PRA staff and obtain feedback.
09/20/2018 SERP held. SERP agrees with moving forward with preliminary white finding.
09/26/2018 Region 3 informs Clinton Power Station of SERP decision and plans to formally communicate the SERP results by phone call prior to issuing the "choice" letter.
11/21/2018 90 Day ROP clock expires
From: Kozak Laura To: Lara Julio: Louden Patrick: Riemer Kenneth: Cameron Jamnes: Stoedter Karla: Shuaibi Mohammed: QJm.en.
~ ; Hanna John Cc: Mitman Jeffrey: Franovich Mike: F ~: Groom Jeremy: Dickson Billy Subject : Clinton Date: Thursday, December 20, 2018 7:53:38 AM (b )(5)
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Note to requester: Attachment is a non-responsive record due to clarifying the request to exclude licensee originated documents.
From: Kozak Laura To : Phillips Charles Cc : Mitman Jeffrey Subject : Clin ton Date: Thursday, December 20, 20 18 11 :06 :00 AM Attachments: 2017 Training Material on DG Air Start Flow Path.pd!
Chuck Could you take a quick look at the attached? Exelon sent this material to demonstrate the training on the air start system. Please look in particular at pages 56 and 57. Are the valves that are the subject of the PD even on the diagrams?
Thanks Laura
Note to requester: Attachments are non-responsive records due to From : Kozak Laura clarifying the request to exclude To : Phillips Charles licensee originated documents .
Subject : Clinton post regulatory con ference information Date: Thursday, December 20 , 20 18 8 :28 :00 AM Attachments: exelon letter.pd!
SRO Surveys lredactedl.pdf CPS Shift Manager Surveys Regarding ELAP Scenarios /redacted} Qdf Chuck I am concerned about the completeness and accu racy of the information that Clinton provided. Wou ld like a sanity check from you?
Attached is the letter, the SRO (not Clinton) surveys, and the Clinton shift manager surveys . I tri ed to highlight the areas of conflict. Please read the letter first , then the other documents.
Thanks Laura
From: Kozak Laura To: Lara Julio: ru.: Riemer Kenneth: Cameron Jamnes: Stoedter Karla: Shuaibi Mohammed: O"Brien Kenneth :
Hanna John Cc: Mitman Jeffrey: Franovich Mike: F ~: Groom Jeremy: Dickson Billy
Subject:
Clinton Date: Thursday, December 20, 2018 7:53:38 AM (b)(5)
- g. The resource burden to perform an SOP analysis is normally considered appropriate if it increases stakeholder understanding of the basis for potentially risk significant conditions, especially when an inspection findinq is believed to be greater than Green. However it is appropriate due to SOP timeliness considerations for the staff to cease further effort to refine or review an analysis, acknowledqe the limitations and uncertainties, and proceed to a final determination using best available information and reasonable technical or Issue Date: 06/16/16 6 0308 Attachment 3 probabilistic judgments. When making the decision to continue further review, especially when the additional review will cause an issue to be untimely, it is essential for the analysts and decision makers to keep in perspective that the purpose of the SOP assessment is to determine what action the staff should take (e.g., supplemental inspection) as a result of the inspection finding. Experience with the SOP since its inception has shown that the resources expended for additional reviews are often not commensurate with the final risk significance determination of the degraded condition and the additional actions taken by the staff.
Note to requester: Attachment is a non-responsive From: Kozak Laura record due to clarifying the request to exclude licensee To: Mitman Jeffrey oriainated documents.
Subject : FW: Omitted Pages Date: Thursday, Decem ber 20, 2018 12 :31 :00 PM Attachments: Attachments - Omitted Interview Pages pdf I will put on share point From: Sa nders, Garrett R:(GenCo-Nuc) [1]
Sent: Thursday, December 20, 2018 12:29 PM To: Koza k, Laura <Laura.Kozak@ nrc.gov>; Sanchez Santiago, Elba <E lba .SanchezSantiago@nrc.gov>
Cc: Shelton, Dale A:(GenCo-N uc) <Dale.Shelton@exeloncorp.com>
Subject:
[Externa l_Sender] Omitted Pages Laura/El ba, The omitted pages from Attachment 6 (Exelon Letter RS-18-146) are provided in the attached.
Please let me know if you have any quest ions or require f urt her informat ion on the attached .
Garrett Sanders Clinton Power Station Regu latory Assu rance (217) 937-2803 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 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 respons.ible 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 E mail communication. Exelon will not accept any liabi lity in respect of such communications. -
EXCIP
From: Kozak Laura To: Giessner John Subject : FW: response to Exelon Date: Thursday, December 20, 2018 4:26:24 PM Attachments: Clinton Regulatorv Conference information reauest.docx.
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From: Kozak, Laura Sent: M onday, December 17, 2018 2:09 PM To: Cameron, Jamnes <Jamnes.Cameron@nrc.gov>; Riemer, Ken net h <Ke nneth.Riemer @nr c.gov>
Subiect: RE: resoonse t o Exelon (b)(5)
From: Cameron, Jamnes Se nt: M onday, December 17, 2018 1:57 PM To: Riemer, Kennet h <Kenneth Rjemer@nrc gov>; Kozak, Lau ra <Laura Kozak@nrc gov>
Subject:
Re : response to Exelon (b)(5)
From: Riemer, Kenneth Se nt: M onday, December 17, 2018 10:54:32 AM To: Kozak, Laura; Cameron, Jam nes
Subject:
RE: response to Exelo n From: Kozak, Laura
Sent: M onday, December 17, 2018 8:55 AM To: Riemer, Kennet h <Kenneth.Riemer@nrc.gov>; Came ron, Jamnes <Jamnes.Cameron@nrc.gov>
Subject:
response to Exelon See attached for some input to a response letter.
Clinton Regulatory Conference Notes New information: 5 areas of new information to be considered.
Battery Life
- Battery life extension evaluation to support 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> battery life Recovery of the DG
- Copy of training material referenced in slide 9 "Assumption 13"
- Copy of the completed questionnaires sent to the 28 SROs as referenced in slide 18 Copy of the completed surveys provided to the six CPS shift managers referenced on slide 18
- Copy of time validation described in slide 19
- Copy of procedure(s) and training (including shutdown simulator exercises) that would direct closure of the shutdown cooling valve§. as referenced in slide 10
- Copy of HEP analysis for operator action to close the shutdown cooling valves referenced in slide 45 Pressure Control
- Copy of procedures and training (including shutdown simulator exercises) to support maintaining RPV pressure below 100 psig without low pressure injection as discussed on slide 45.
Division 3 Cross-tie
- Copy of time validations for evolutions described in slides 10 (cross-tie)
Questions (not necessarily related to new information):
- Any additional shutdown SBO training? If so provide training materials.
- Would the control room annunciators be impacted by the DC load shed?
- Any additional FLEX or cross-tie training materials to provide?
- What was the water level in the reactor vessel during the timeframe when both Division 1 and Division 2 diesels were unavailable?
- Exelon indicated that the credit we were giving re FLEX was inconsistent with the NRC FLEX SER. Please supplies details.
From: Cameron Jamnes To: Kozak Laura: Lara Julio: Louden Patrick: Riemer Kenneth: Stoedter Karla: Shuaibi Mohammed: QJme.o.
1Se.oae1h; Hanna John Cc: Mitman Jeffrey: Franovich Mike: F ~: Groom Jeremy: Dickson Billy Subject : Re: Clinton Date: Thursday, December 20, 2018 9:49:17 AM (b)(5)
From: Kozak, Laura Sent: Thursday, December 20, 2018 7:53:36 AM To: Lara, Julio; Louden, Patrick; Riemer, Kenneth; Ca meron, Jamnes; Stoedter, Ka rla; Shuaibi, Mohammed; O'Brien, Kennet h; Hanna, John Cc: M itman, Jeffrey; Franovich, Mike; Fong, CJ; Groom, Jeremy; Dickson, Billy
Subject:
Clinton (b)(5)
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From: Mitman Jeffrey To : Kozak Laura Subject : HEPs Quantification Date: Friday, December 21 , 2018 4:03:01 PM In our ongoing debate/argument on HEP quantification , I thought we might use comparisons to existing and non-controversial HEPs. For example, when Exelon states that our crosstie value of 23% is too large because it is straightforward and well trained, we can compare it to the value for placing SPC inservice (in 1O hours) of 5E-4, manually starting RCIC of 2E-3, or failure to depressurize during a MLOCA of 2E-2.
If we had time, we could ask SROs (both internal and external) to do one to one comparisons of the HEPs we're interested in against 3 or 4 non-controversial HEPs. For example:
Is the crosstie 1) less, 2) about the same or 3) more likely to fail than SPC?
Is the crosstie 1) less, 2) about the same or 3) more likely to fail than depressurization?
Is the crosstie 1) less, 2) about the same or 3) more likely to fail than manually starting RCIC?
This comparison wa of illustratin HEP values
- reduce some of the misunderstanding. (b)(5)
!(b)(5) !
Jeff Mitman
Note to requester: The attachment to this email has been withheld in its entirety under FOIA Ex. B5 From: Ruiz Robert (deliberative process privilege).
To : Qfil1l! ; QB.fill!
Cc : Heck Jared: MiJlyng YikJorja: QbandraJbil Prema Subject : End of Cyc le Operating Experience Report Date: Monday, December 31, 2018 1:38:50 PM Attachments: EOC OE Note-2019.pdf All ,
Please find the attached OpE report for your reference , as we will be discussing this during the EOC meetings.
The purpose of this Note is to provide information on relevant OpE issues evaluated over the past year that should be considered in the inspection planning process because of their potential safety significance and relevance across the industry.
Note: there are a couple Region Ill sites mentioned .
Please be prepared to talk about these insights (if they apply to you) and any other insights you may have on industry trends.
Thank you!
Rob Ruiz Region Ill OpE Coordinator
Note to requester: Attachment is a non-responsive record due to clarifying the request to exclude licensee From: Kozak Laura originated documents .
To : Mitman Jeffrey Subject : FW: C1R18 SSMP (FINAL) (002) .pdf Date: Tuesday, June 05, 2018 9:03 :00 AM Attachments: C1R18 SSMP /FINAL} 1002}.pdf FYI - Clinton's shutdown risk plan for the outage .
From: Sanchez Santiago, Elba Sent: Monday, June 04, 2018 4 :38 PM To: Kozak, La ura <Laura .Kozak@ nrc.gov>
Subject:
C1R18 SSMP (FINAL) (002).pdf
- Laura, You were correct. There was a page missing in what I sent you. Attached is the full document. I apologize for the confusion .
- Thanks, Elba
From: Lara Julio To: Miller Chris: Franoyich Mike: Wilson Georce Subject : RE: Outreach: Post Clinton EOG SERP regroup Date: Tuesday, February 19, 2019 11 :23:00 AM I can support 12 EST, on thurs Thanks!
From: M il ler, Chris Sent: Tuesday, February 19, 2019 10:20 AM To: Franovich, M ike <Mike.Franovich@ nrc.gov>; Lara, Julio <Julio.Lara@nrc.gov>; Wilson, George
<George.Wilson@nrc.gov>
Subject:
Re: Outreach: Post Clinton EDG SERP regroup Fully support. Thursday noon EST works for me. Thanks Mike chris On: 18 February 2019 17:00, "Franovich, Mike" <Mjke.Franovjch@nrc.gov> wrote:
SES only Julio, George, and Chris, (b)(5)
In the spirit of moving forward, I have a very short, options based proposal in the works that will hopefully resolve the impasse. My goal is to avert a lengthy second SERP meeting by achieving management alignment before-hand. There are some management perspectives and dynamics from each of our vantage points that may be best discussed amongst ourselves.
If we could have a discussion later this week and possibly strategize, it would be greatly appreciated. I will share the three options (includes White and Green) in advance of the discussion. Looking at your calendars I checked what could be available. Perhaps lunch-time (EST) this Thursday may work.
- Best,
Note to requester: The attachments to this email have been withheld in their entirety under FOIA Ex. 85 (deliberative process privilege).
From: Lambert Kenneth To: Lara Julio: Orlikowski Robert: O"Brjen Kenneth: Sanfilippo Nathan : Roberts Darren: Gjessner John: ~
LilJ.l.t:il; Hanna John Cc: Sanchez Santiago Elba; Sargis Daniel; Phillips Charles: Mancuso Joseph; St. Peters Courtney: 81'.aJ:al1o Gumoty Diana
Subject:
FW: NRR Areas of Disagreement for Clinton Follow-up SERP (EA-1 8-104)
Date: Tuesday, February 26, 2019 3:05:00 PM Attachments: PBA Areas of pjsaareement Clinton docx DIBS Areas at Disagreement Clinton docx Attached are the NRR ORA and DIRS position papers for the Clinton follow-up SERP on Thursday.
Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission 630-810-4376 kenneth .lambert@nrc.gov From: Casey, Lauren Sent: Tuesday, February 26, 2019 2:26 PM To: M arshfield, M ark <Mark.Marshfield@nrc.gov>; Lambert, Kenneth <Kenneth.Lambert@nrc.gov>
Cc: Torres, Edgardo <edgardo.torrescollazo@ nrc.gov>
Subject:
NRR Areas of Disagreement for Clinton Follow-up SERP (EA-18-104)
Good afternoon, Attached for OE and Region Ill's distribution are NRR's areas of disagreement for discussion at Thursday's follow-up SERP.
Thank you ,
Lauren R. Casey NRR Enforcement Coordinator U.S. Nuclear Regu latory Commission 301 -415-1038
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From: Lara Julio To : Lambert Kenneth Subject : Clinton_FinalSERP_R3 .pdf Date: Wednesday, February 27, 2019 8:44:00 AM Attachments: Clinton FinalSERP R3.pdf.
Importance: High
- Ken, Pis forward as appropriate.
Thanks Julio
February 27, 2019 Clinton Preliminary White Finding (EA-18-104)
Region Ill Comments - J . Lara (b)(5)
From: Lambert Kenneth To: Lara Julio: Orlikowski Robert: O"Brjen Kenneth: Sanfilippo Nathan : Roberts Darren: Gjessner John: ~
Law:a; Hanna John: Cameron Jamnes Cc: Sanchez Santiago Elba: Sargis Daniel; Phillips Charles: Mancuso Joseph; St. Peters Courtney: 81'.aJ:al1o Gumoty Diana: Marshfield Mark Subject : FW: Updated Clinton OE Input Date: Wednesday, February 27, 2019 7:20:17 AM
- Folks, See the emails below regarding OE's position on the Clinton EDG issue for tomorrow's follow-up SERP Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission 630-810-4376 kenneth.lambert@nrc.gov From: Ma rshfield, Mark Sent: Wednesday, February 27, 2019 6:40 AM To: Casey, Lauren <La uren.Casey@nrc.gov>; Lambert, Kenneth <Kenneth. La mbert@ nrc.gov>
Subject:
Updated Clinton OE Input More data from George.
Mark M.
From: Wilson, George Sent: Wednesday, February 27, 2019 7:38 AM To: M arshfield, M ark <Ma rk. Ma rshf ield@nrc.gov>
Subject:
Re: NRR Areas of Disagreement for Cl inton Follow-up SERP (EA-18-104)
(b)(5)
On: 27 February 2019 06:32, "Wilson, George" <George Wjlson@nrc gov> wrote:
My one pager is included in DRA Mike Franovick's but only the first two concerns
On: 27 February 2019 06:15, "Marshfield, Mark" <Mark.Marshfield@nrc.gov> wrote:
- George, Paul asked me to resend this, this morning.
Mark M.
From: Marshfield, Mark Sent: Tuesday, February 26, 2019 3:36 PM To: Wilson, George <George.Wilson@nrc.gov>
Cc: Peduzzi, Francis <Francis Peduzzi@orc gov>; Peralta, Juan <Juan Peralta@nrc gov>; Casey, Lauren <Lauren Casey@nrc gov>
Subject:
FW: NRR Areas of Disagreement for Clinton Follow-up SERP (EA-18-104)
- George, NRR has provided the following documents for your review prior to the panel on Thursday, 2/28.
They request that you provide to Lauren Casey for distribution your "one-pager" for review by their voting members.
Thank you ,
Mark Marshfield OE/ EB I have printed out copies for George and provided to Nasreen since his e-mail address is apparently not working.
From: Casey, Lauren Sent: Tuesday, February 26, 2019 3:26 PM To: Marshfield, Mark ; Lambert, Kenneth <Kenneth Lambert@nrc gov>
Cc: Torres, Edgardo <edgardo torrescoll azo@nrc gov>
Subject:
NRR Areas of Disagreement for Clinton Follow-up SERP (EA-18-104)
Good afternoon, Attached for OE and Region Ill's distribution are NRR's areas of disagreement for discussion at Thursday's follow-up SERP.
Thank you ,
Lauren R. Casey NRR Enforcement Coordinator
U.S. Nuclear Regulatory Commission 301-415-1 038
From: Lara Julio To: Giessner John Cc: Roberts Parcell Subject : FW: Clinton SERP Date: Thursday, February 28, 2019 8:35:00 AM This thought is in Mike Franovich's paper.
He broached with me last night in our conversation.
Have not given it much thought till now From: M iller, Chris Sent: Thursday, February 28, 2019 8:07 AM To: Lara, Ju lio <Julio.Lara@nrc.gov>
Subject:
Cl inton SERP Hi Julio, (b)(5) thanks chris Christopher Mi ller Director, Division of Inspection and Regional Support Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission 301-415-1004
Note to requester: Attachment is a non-responsive record due to clarifying the request to exclude licensee originated documents.
From: Lara Julio To: franovich Mike: Miner Chris: Wilson George Subject : RE: Clinton - Outline of Final Significance Determination Response rev 1.docx Date: Thursday, February 28, 2019 8:52:00 AM Attachments: 1456 001 pdf imaaeoo1 .pna All, I am attaching the most recent End of CYcle package for Clinton.
Based on Chris' and Mikes feedback, perhaps we could start with an overall summary of Clinton performance.
Im running in-between meetings.
From: Franovich, M ike Sent: Thursday, February 28, 20 19 8 :46 AM To: Lara, Julio <Julio. Lara@nrc.gov>; Miller, Ch ris <Ch ris.Mi lle r@nrc.gov>; W ilson, George
<George.Wilson@nrc.gov>
Subject:
RE : Clinton - Outline of Fina l Significa nce Determi nation Response rev l.docx (b )(5)
From: La ra, Julio Sent: Wednesday, February 27, 2019 6:36 PM To: Franovich, M ike <M ike Franovich@nrc gov>; Miller, Chris <Chris M il ler@nrc gov>; Wilson, George <George.Wilson@ re.gov>
Subject:
Clinton - Outline of Final Significance Determinat ion Response rev l.docx Gents, The original email wh ich provided SERP information contained 2 files: SERP package and
an outline of a proposed Final SOP letter (assuming White significance).
I am not sure if we as SERP members have focused on the second file , which I am attaching to this email.
I have taken the liberty to highlight some specific text in BLUE relating to some of the issues before us. A quick read of the document may provide further background analysis to further expand on the summarized points within the SERP package.
Thanks Julio Julio Lara, P.E.
Division Director Division of Reactor Projects, RIii 630-829-9600 0- F* " ;,. * *"
- IJ' mpoK' rin 1/1
From : Kozak Laura To : Riemer Kenneth Subject : Clinton Date: Thursday, January 03 , 2019 8:42:00 AM Attachments: !(b )(5) !
Ken This is draft. I extracted the important statements from our inspection report, the licensee presentation , the licensee cover letter and white paper. Then I extracted the relevant statements from the SROs. Finally , I drafted a 50 .9 violation . I balded the most important statements.
I will try to talk to Jared this week.
Laura
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From: Kozak Laura To: Mitman Jeffrey
Subject:
Clinton Date: Thursday, January 03, 2019 1 :55:00 PM Attachments: imageoo1 png Jeff Happy New Year! I'm back at work whenever you are in and want to talk. I was reviewing the batterv calculation brieflv todav. l(b)(S) I (b)(5)
Laura (b )(5)
From: Kozak Laura To : Lara Julio Subject : Clinton Date: Thursday, January 03 , 2019 8:26:00 AM Attachments: !(b)(5) !
This is draft, but you can see some of the relevant statements .
I bolded the most important statements.
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From: Kozak Laura Note to requester: Attachments are either non-To: Riemer Kenneth: Lara Julio responsive records due to clarfying the request to Subject : FW: Clinton Date: Thursday, January 03, 2019 10:27:00 AM exclude licensee originated documents or have has been withheld in their entirety under FOIA Ex. B5 Attachments: CU 2018 051 ERRATA /non-public} docx CPS Div 2 QG Reg Cont Presentation Ol 18}(0]) pdf ( deliberative process privilege).
RS-l B-J46 /Attachments 1 and 21 pdf SRO surveys <redacted) pdf Clinton incomplete and inaccurate docx FYI From: Kozak, Laura Sent: Thursday, Jan uary 03, 2019 10:11 AM To: Heck, Jared <Jared.Heck@nrc.gov>
Subject:
Clinton Jared (b)(5)
Please take a look and let's discuss further.
Laura
From: Kozak Laura To: Lara Julio: Orlikowski Robert Cc: Hanna John
Subject:
Fw: Clinton SDP Hours Date: Saturday, April 06, 2019 9:19:02 AM (b)(5)
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Laura
From: Aird, David Sent: Friday, Apr il 5, 2019 11:21 AM To: Ko zak, Laura Cc: M it ma n, Jeffrey; Mill er, Chris; Dickson, Bi ll y; Bowma n, Gregory; Garmoe, Alex; Aird, David
Subject:
Clinton SD P Hours Lau ra, Just got fin ished aggregating t he hours charged fo r the Clinton W hite findi ng (EA-18-104). The totals are shown in the tab le below . As a reminder, these are only the bill able hours ch arged by primari ly Jeff and yourself . Othe r support (i.e., manage ment t ime, OE, DIRS staff) is not avai lable. The data is discreti zed by the individual st aff mem ber on a per day basis . If t here are addition al/altern ati ve sl ices of t he data that you th ink wo uld be helpful, pl eas e let me know .
Report Activity Hours Reactive Rpts: Clinton - FB-OR-INSPECTION SIGNIFICANCE DETERMINATION 235.75 2018050 (SIT - TBD) PROCESS (SOP}
Reactive Rpts: Clinton - FB-OR-INSPECTION SIGNI FICANCE DETERMINATION 182.75 2018051 (Prelim White) PROCESS (SOP)
Final Determination - FB-OR-INSPECTION SIGNI FICANCE DETERMINATION 448 2018092 (Final White) PROCESS (SOP )
Grand Total 886.5
- Regards, Dave
From: Ng Raymond To: Bogedain Poni Subject : RE: Clarification of boiler plate wording on violations Date: Monday, January 07, 2019 11:53:00 AM (b)(5)
(b)(5)
Thanks, Raymond Ng Project Engineer Division of Reactor Project s, RIii 630-829-95 74 From: Bogedai n, Doni Sent: M onday, Ja nuary 07, 2019 10:20 AM
To: Ng, Raymond <Raymo nd. Ng@nrc.gov>
Subject:
Clarification of boi ler plate wording on violations Hi Ray, (b )(5)
Thanks!
{ilf;;111 rfifor7erlai11 U.S. Nuclear Regulatory Commission Fermi 2 and Davis-Besse Resident Inspector Office Assistant 630-829-9987 (Fermi) 630-829-9983 (Davis-Besse)
From: Kozak Laura To : Mitman Jeffrey Subject : Clinton Date: Monday, January 07, 2019 9:29 :00 AM Attachments: !(b )(5)
This is FYI. I will update you when we talk.
Laura
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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 : Mitman Jeffrey Subject : Clinton schedule Date: Tuesday, January 08 , 2019 6 :50 :52 AM Attachments: Janua_ry 8 Clinton update .docx.
Jeff I'd li ke to send an update on the review to SER P members and other interested parties . What do you think of the attached?
Laura
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Note to requester: The attachment to this email has been withheld in its entirety under FOIA Ex.
From: Kozak Laura B5 (deliberative process privilege).
To : Mitman Jeffrey Subject : Clin ton update Date: Tuesday, January 08 , 2019 3 :47:42 PM Attachments: Janua_ry 8 Clinton update .docx.
see attached
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From: Kozak Laura To : Mitman Jeffrey Subject : Clinton battery life Date: Wednesday, January 09 , 2019 8:09 :00 AM Jeff (b)(5)
Your call, but I wanted to share those thoughts.
Laura
Note to requester: The attachment to this email has From : Kozak Laura been withheld in its entirety To : Lambert Kenneth : Hanna John under FO IA Ex. B5 Subject : FW: Clinton SDP update (deliberative process Date: Wednesday, January 09, 2019 10:44:00 AM privilege).
Attachments: Janua_ry 8 Clinton update .docx.
FYI From: Kozak, Lau ra Sent: Tuesd ay, January 08, 2019 3:56 PM To: Lara, Jul io <Ju lio. Lara@nrc.gov>; Orl ikowsk i, Robert <Robert.Orl ikowski@n rc.gov>; O'Brie n, Kenneth <Kenneth.O'Brie n@nrc.gov>; Riemer, Kenneth <Kenneth.Riemer@nrc.gov>; Cameron, Jamnes <Jamnes.Camero n@nrc.gov>; Stoedter, Ka rla <Ka rla.Stoedter@nrc .gov>; Sanchez Santiago, Elba <E lb a.SanchezSantiago@nrc.gov>; Phi lli ps, Cha rles <Charles. Phi lli ps@nrc.gov>; M itman, Jeffrey
<Jeffrey.Mitma n@ nrc.gov>; Groom, Jeremy <Jeremy.Groom@nrc.gov>; M il ler, Chris
<Chris.Mi ller@ nrc.gov>; Dickson, Bil ly
Subject:
Clin ton SDP update Please see the attached schedule for review of Clinton information provided December 14. A brief update on our progress is also provided .
Our goa l is to complete the review and revised risk evaluation by January 31 for a SERP in early Fe bruary Please contact me or Jeff with any questions .
Lau ra
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From: Helton Donald To: Gibbs Russell Cc: Garmoe Alex
Subject:
Bi-weekly SDP Highlig hts Date: Friday, July 20, 2018 4:18:00 PM
- Russ, It's that time again ...
- 1(b)(5)
- ROP Public meeting on July 19th went well - no adverse reaction to the 0609 activities, with some good questions being asked about the Appendix D revision out for public comment
- The Appendix D external comment period has been extended through September 20, based on a request from NEI
- Planning/activity continued on preparing some clarifying guidance on how to process Tl-193 SDPs, sun-setting of Appendix 0 , slides for the DDCM SOP briefing, etc.
- l(b)(5)
Since I'm out for much of the next 2 weeks, and since you'll be in the office in August, I'll suspend these bi-weekly updates until you go to Japan in September ...
Hope all is well.
Don From: Helton, Dona ld Sent: Friday, July 06, 2018 3:11 PM To: Gibbs, Russell <Russell.Gibbs@nrc.gov>
Cc: Garmoe, Alex <Alex.Garmoe@nrc.gov>
Subject:
Bi-weekly SDP High li ghts
- Russ, I realize you are on leave, but for the sake of cadence, here are your bi-weekly highlights:
- Antonios Zou lis has been named as See-Meng's replacement.
- 0609 Appendix D has gone out for external comment.
- 0609 Appendix I has gone out for internal comment.
- I received your comments on the draft of 0609 Appendix M, and we'll factor these in when we address the totality of the internal comments. Separately, the CTA brief on the 0609M extension request went smoothly.
I think that hits the high points ... Hope you are enjoying your leave, Don
From: Helton Donald To: Gibbs Russell Subject : RE: Bi-weekly SOP Highlights Date: Monday, August 20, 2018 11 :20:00 AM Will do.
From: Gibbs, Russell Sent: Monday, August 20, 2018 11:15 AM To: Helton, Donald <Donald.Helton@nrc.gov>
Cc: Garmoe, Alex <Alex.Garmoe@nrc.gov>
Subject:
RE: Bi-weekly SOP High lights (b )(5)
We three should meet with David to offer our individual perspectives. Please Don add this meeting to the transition plan you develop.
Thanks!
From: Helton, Donald Sent: Friday, August 17, 2018 3:59 PM To: Gibbs, Russell <Russell .Gibbs@nrc.gov>
Cc: Garmoe, Alex <Alex.Garmoe@ nrc.gov>
Subject:
RE : Bi-weekly SOP High lights My understanding is t hat Dav id Aird (start ing in mid-Septem ber ) will t ake over a lot of t he day-t o-day t hings I've been worki ng on . David has PRA experience (mast er's under Ali Mosleh and a few years doing ASP analyses), and a little inspection experience, so t hat shou ld be a good f it. I' ll be comi ng up w ith a simple t ransition plan in t he coming few w eeks to try and get everyone on t he same page as to who is doing w hat and whe n ...
From: Gibbs, Russell Sent: Friday, August 17, 2018 3:55 PM To: Helton, Donald <Donald.Helton@nrc.gov>
Cc: Garmoe, Alex <Alex Ga rmoe@ nrc gov>
Subject:
Re: Bi-weekly SDP Highlights As always lots going in with the SOP Program! Gotta talk to Greg about what he's thinking on who will take over when you leave as I will be in Japan. And now I'm working Transformation. Without help, that' s a full plate. Right Akex!
On: 17 August 2018 15:40, "Helton, Donald" <Donald He)ton@nrc gov> wrote:
- Russ, Resuming t he habit after a layoff from vacation ...
- SDPs :
o Clinton EDG SDP ongoing; SERP in Septembe r o Fermi RHR SW SDP underway; IFRB is next week o Peach Bottom (2 issues) still at regional level
- 0609 Appendix I and M interna l com ment periods ended; lot of feedback from R3 on M; I should be made publicly avai lable (draft ) next week
- 0609 Appendix H should go out for interna l comment in the next week or so
- 0609 Appendix O - NRR/DLP+DRA+DIRS division management agreed with sun-setting as pa rt of Appendix A revision
- DDCM presentation o n FLEX - you saw t he slides
- Discussing 0609 FBF status (thi nk red DIRS metric) with Chris/M ike on 8/28
- Cheers, Don From: Helton, Donald Sent: Friday, July 20, 2018 4:19 PM To: Gibbs, Russell <Russell .Gibbs@nrc.gov>
Cc: Garmoe, Alex <Alex Garmoe@nrc gov>
Subject:
Bi-weekly SDP High li ghts
- Russ, It's that time again ...
- l(b)(5) I
HQ perform a DRE.
- ROP Public meeting on July 19th went well - no adverse reaction to the 0609 activities, with some good questions being asked about the Appendix D revision out for public comment
- The Appendix D external comment period has been extended through September 20 , based on a request from NEI
- Planning/activity continued on preparing some clarifying guidance on how to process Tl -193 SDPs, sun-setting of Appendix 0 , slides for the DDCM SOP briefing ,
etc.
- rb)(5)
Since I'm out for much of the next 2 weeks, and since you 'll be in the office in August, I'll suspend these bi-weekly updates until you go to Japan in September. ..
Hope all is well.
Don
From: Helton Donald To: Garmoe Alex Subject : RE: Clinton SERP?
Date: Thursday, September 06, 2018 10:09:00 AM OK. I sensitized Laura to the metric discussion between DIRS and Ho, and to the standing agenda item during the bi-weekly call. .. She plans to proceed as she has been (unless/until directed otherwise), but to make sure her management is sufficiently aware of the status/constraints for the 9/ 14 and 9/28 bi-weeklies ...
Thanks for making me aware ...
From: Ga rmoe, Alex Sent: Wednesday, September 05, 2018 5:34 PM To: Helton, Donald <Donald.Helton@nrc.gov>
Subject:
RE: Clinton SERP?
(b)(5)
From: Helt on, Donald Sent: Wednesday, Sept ember 05, 2018 5:26 PM To: Garmoe, Alex <Alex Garmoe@nrc gov>
Subject:
RE: Clinton SERP?
I do not know (though my guess is that the answer is no). The Clinton SOP is squarely in HQ's domain thanks to the planning SERP and the HQ-led DRE, and that one is on a better success path at the moment. The Fermi SOP wouldn't really be on our radar yet if it weren't for the fact that I was involved at one point consulting as a SME (wearing my RES hat).
That one's dicier, and as a lways, will be fundamentally affected by whether it is GTG or not.
Do you want me to give Laura a call tomorrow and let her know that the SOP timeliness metric is getting lots of attention on this end, and her management might get a question on the 9/14 call?
From: Ga rmoe, Alex Sent: Wednesday, September 05, 2018 3:18 PM To: Helton, Donald <Donald He ltoo@orc gov>
Subject:
RE : Clinton SER P?
Don, I aooloaize in advance for 1iumoinq ahead of vou a bit,l(b)(5) I (b )(5)
Anyway, Greg was wondering if Region Ill was planning to use the standing SDP metric time on the bi-weekly DD Friday call agenda to discuss these two items. I don't know - do you?
Thanks, Alex From: Helton, Donald Sent: Tuesday, Septem ber 04, 2018 2:58 PM To: Garmoe, Alex <Alex Garmoe@nrc gov>
Subject:
RE: Clint on SERP?
Agreed on the timing in your 1st paragraph.
Agree on your remarks in the 2 nd paragraph.l(b)(5)
(b )(5)
From: Garmoe, Alex Sent: Tuesday, September 04, 2018 2:53 PM To: Helton, Donald <Donald Helton@nrc gov>
Subject:
RE: Clinton SERP?
Sounds good - probably best to do the SDP items right up front at the ROP meeting (around 9am eastern) so you'll be free in time to attend the SERP, which can hopefully be around 10:30am eastern.
From: Helton, Donald Sent: Tuesday, September 04, 2018 2:48 PM To: Garmoe, Alex <Alex Garmoe@nrc gov>
Subject:
RE : Clinton SERP?
OK. That will represent a conflict for me if the Clinton SERP does occur that day, but so be it. I'll go to the ROP Monthlly for the portion on SOP (including my remarks obviously), and hopefully it won't overlap completely with the SERP.
For what it is worth, below are my "key messages" based on today's and past discussions with Laura about those 2 SDPs:
Clinton:
- Analysis is proceeding in a timely fashion , but meeting the SOP metric will be tight
- NRG evaluation may differ significantly from the licensee's, with HRA modelling assumptions being the key difference
- SERP tentatively planned for September 20th (b)(5)
From: Ga rmoe, Alex Sent: Tuesday, Septem ber 04, 2018 2:40 PM To: Helt on, Donald <Donald Helton@nrc gov>
Subject:
RE: Clinton SERP?
Yes, the ROP monthly is going to be 9/20 in the morning. We're hoping it will be a half day meeting but the list of agenda topics is still being developed.
From: Helton, Donald Sent: Tuesday, September 04, 2018 2:39 PM To: Garmoe, Alex <Alex.Garmoe@nrc.gov>
Subject:
RE: Clinton SERP?
What timing ... I was planning to reach out to you about this ... I talked with Laura this morning , and it looks like the SERP will be on 9/20 @ 9 or 9:30 (subject to change of course) . That means it potentially conflicts with the ROP Monthly. Was that going to be in the AM?
From: Garmoe, Alex Sent: Tuesday, September 04, 2018 2:07 PM To: Helton, Donald <Donald .Helton@nrc .gov>
Subject:
Clinton SERP?
- Don, Have you heard if the Clinton SERP has been scheduled or any insights on where the risk numbers are coming out? I recall the target was a SERP sometime this month .
- Thanks, Alex
From : Helton Donald To : Garmoe Alex Subject : RE : SRA Call Date: Monday, September 17, 2018 3 :37:00 PM (b)(5) s ongoing or ataw a vo tage regu ator , a o er e main steam 1so at1on , an River Bend (water in EOG lube oil) ... none are clearly GTG at this point. ..
From: Garmoe, Alex Sent: M onday, September 17, 2018 3:25 PM To: Helton, Dona ld <Donald. Helto n@nrc.gov>
Subject:
SRA Ca ll Don ,
I did hop on about half way through the SRA call , after the regions had already reported out. b 5 l'b(b_)(5)) _ _ ___,I Anything to add or correct?
)(_5_
Thanks, Alex
From: Helton Donald To: Aird David Subject : RE: Turnover 2 - Revenge of the Dashboard I Date: Monday, September 24, 2018 11:21:00 AM As I'll keep saying, be vocal about asking for help and telling me when to get out of the way.
I assume you are getting a new number (only because Shana is getting a new number when she moves to 3WFN next week)? I tried to call you a little while ago on your old number, since my phone said that your call to me this A M had come in on that number, but to no avail. That said, I'm not convinced I know how to use this new phone yet, so it could've been my error.
From: Aird, David Sent: M onday, September 24, 2018 10 :55 AM To: Helton, Donald <Donald .Helton@nrc.gov>
Subject:
RE: Tu rnover 2 - Revenge of t he Dashboard !
- Don, Thanks for trying to set me up for success. I am definitely feeling overwhelmed and selfishly would like to stay longer to help with the transition. I want to tread water before people expect me to start swimming.
That aside, I agree with the division of work you proposed. Each meeting we setup or attend helps me gain context and familiarity.
Now if only you could make my VoIP phone work .. .
Dave From: Helt on, Dona ld Sent: M onday, September 24, 2018 10:33 AM To: Aird, David <David Aird@nrc gov>
Subject:
Turnover 2 - Revenge of the Dashboard!
- David, We've reached that point where (for the next couple of weeks) it will be difficult for us, much less others, to know who has what. So that at least you and I can be on the same page, I've migrated my overall tracking list (the thing we've been walking through in our turnover meetings) to Sharepoint. Between that, and the SDP Revs "Dashboard" it should provide a two-stop shop as to who has the lead. In general, I've gone ahead and treated you as the lead for most things, with the following exceptions:
- 1. The ACRS Leading1Indicators activity - the ACRS meeting is on October 4th, and I'll hand that off afterward (though our role is pretty narrow to begin with)
- 2. The ongoing Clinton SOP - When the Choice letter goes out (next week?) will be a
good time to transition that
- 3. The ongoing Fermi SOP - At this point I'm actually only really involved b/c of my RES duties (it is still at the Regional level); the SERP (nominally in early October) will be a good time to trans ition this
- 4. rb)(5)
- 5. DIRS lead for IMC 0609 Appendix H - Since I was pretty involved in formulating the actual changes, it probably makes sense for me to hang on to it until we receive and triage internal comment
- 6. DIRS lead for IMC 0609 Appendix M - Per Greg's request, I'll retain this until January ...
- 7. SERP training - very little activity here, and we 'll transition once we've reached this part of the turnover list on Thursday
- 8. SOP Desktop Guide - Let's talk Thursday ...if I can carve out the time, me taking the first crack might be a good way to trigger thoughts of things that I've forgotten to mention to you .. ..
Don't hesitate to speak up if you think I've gone too far in re-assigning things now, or if you think I'm hanging on to th ings that I shouldn't be . The above notwithstanding , I'll obviously continue to participate and provide context as best I can on the full spectrum of activities.
- Thanks, Don Don Helton Division of Inspection and Regional Support (Rotational)
Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission (301) 415-1545
From: Helton Donald To: Leech Matthew: Aird David Subject : RE: Clinton timeline and 6595 item Date: Wednesday, September 26, 2018 11 :23:00 AM (b )(5)
From: Leech, Matthew Sent: Wednesday, September 26, 2018 11:20 AM To: Helton, Donald <Donald.Helton@nrc.gov>; Aird, David <David.Aird@nrc.gov>
Subject:
RE: Clinton t imeline and 6595 item I haven't heard about the FERMI SDP ....what's the 30 second run down on that one?
From: Helton, Donald Sent: Wednesday, September 26, 2018 11:17 AM To: Mitma n, Jeffrey <Jeffrey.Mitman@nrc gov>
Cc: Aird, David <David Aird@nrc.gov>; Leech, Matthew <Matthew Leech@nrc gov>; Ng, Ching
<Ching Ng@nrc gov>; Kichline, Michelle <Michelle Kicb lioe@nrc gov>
Subject:
Clinton timeli ne and 6595 item
- Jeff, 2 follow-ups from the meeting this morning :
- 1. The timeline I have for the Clinton SDP is below. Certainly let me know if you know something different.
- 2. (b)(5)
so I wonder ...
Don THESE ARE UNOFFICIAL VALUES As of IFRB As of Current Notes on 7/19 Planning SERP Inspection- Event/Condition 5/17/2018 related dates Report Date Date Reactive ~5/24/ 18 Have not Inspection Need confirmed the Determined actual date with the Region SIT Entrance 6/20/2018 Meeting SIT Inspection 6/29/2018 Exit Meeting Re-exit TBD TBD 8/3/2018 SIT Inspection TBD TBD 8/23/2018 Report Issued ROP and Reactive Met by 6/20/18 entrance due to lag between 30 days from the Traditional Inspection discovery of condition on 5/17/18 and when determination a Enforcement Initiation metric the Region determined that a reactive reactive Metrics [E-2) inspection was required 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 I 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 full 11 /21 /2018 90 days from (E-5) E-4 and 0 -1 time is used) inspection report issuance 255-day overall 1/29/2019 255 days from target to the discovery of complete all the activity event/condition SOP-related Initial DRE/SERP 8/29/2018 8/29/2018 9/13/2018 Milestones Package Ready for Review SERP . 9/13/2018 9/20/2018 Choice letter . 9/26/2018 10/2/2018 issued Regulatory . 10/27/2018 11 /9/2018 Conference Final . 11/10/2018 11/23/2018 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: Kozak Laura To: Helton Donald Subject : RE: Fermi responses from 9/28 phone call Date: Monday, October 01 , 20181:47:15 PM
- 1 ,l(b)(5)
- 2, I think you might have m is-heard. I wanted the systems that would remain available.
- 3, I have to review later too. Must write that Clinton letter!
Thanks for being so on top of this and helpful.
Laura From: Helton, Donald Sent: M onday, October 01, 2018 12:30 PM To: Kozak, Laura <Laura.Kozak@ nrc.gov>
Subject:
RE: Fermi responses from 9/28 phone cal l Thanks.
(b )(5)
Thx, Don From: Kozak, Laura Sent: M onday, October 01, 2018 1:07 PM To: Helton, Donald <Donald.Helton@n rc.gov>
Subject:
FW: Fermi responses from 9/28 phone call From: M ichael J Koenema nn [ma iltow ichael koenemann@dteenergy com]
Sent: Monday, October 01, 2018 11:36 AM To: Kozak, Laura <Laura Kozak@nrc gov>
Cc: Michael A Lake <michaeLlake@dteenergy.com>
Subject:
[Externa l_Sender] Fermi responses from 9/28 phone call Hi Laura, Here are responses for the information you asked for on t he 9/28 phone ca ll :
(b )(5)
(b)(5)
From: Helton Don To: Helton Pon Subject : SRA Call Date: Monday, January 14, 2019 4:20:51 PM Region 1: Chris
- 1(b)(5)
- Commissioner Caputo was visiting R-1 and interacted with Frank ... mostly met wit h sen ior management Region 2: Scott
- (b)(5)
Region 3: John/Laura
- Still working on Clint on W hite finding Region
- ,...r4:
b-.
)(....
5)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
RES:
- r DIR$:
)(5)
- r (S) 1 ORA:
~., .b,)(.,S)r-------------,1
From: Garmoe Alex To: Bowman Gregory Subject : FW: Clinton - Path forward Date: Tuesday, February 19, 2019 9:23:00 AM I'm more comfortable with Chris's proposed approach - meeting with ORA and discussing with the Region before meeting with Ho. Any consideration of qualitative factors cannot be fully considered without the Region involved since they would have the most facts to feed into the qualitative considerations.
From: M il ler, Chris Se nt: Tuesday, February 19, 2019 9:21 AM To: Casey, Lauren <La uren.Casey@nrc.gov>
Cc: Dickson, Billy <Bi lly.Dickson@nrc.gov>; Aird, David < David .Aird@nrc.gov>; Bowman, Gregory
<G regory.Bowman@ nrc.gov>; Garmoe, Alex <Alex.Garmoe@nrc.gov>; Franovich, M ike
<M ike. Fra novich@ nrc.gov>
Subject:
Re: Cli nton - Path forw ard I would like to meet with M ike a nd ORA first, hopefully with some discussion on the specifics of the assumptions and process that led to our p ackage- hopefull y that would inc lude a discussion with the Region. Then a meeting with Ho to discuss the NRR position. Then the re-SERP. Billy has some questions I would like to discuss with that part one discussion.
Thanks chris On: 19 February 2019 06:19, "Casey, Lauren" <Lauren,Casey@nrc.gov> wrote:
Hi Chris, (b )(5)
(b)(5)
Thanks, Lauren R. Casey NRR Enforcement Coordinator U.S. Nuclear Regulatory Commission 301-415-1 038
From: Miller Chris To: Dickson Billy: Giroom Jeremy: Bowman Gregory Subject : Re: CPS Submittal Status Update Date: Saturday, December 15, 2018 11:52:59 AM Please check in with Ho on his concern with this issue. Probably should check with M ike Franovich first. I sent the info from Lauren to Ho because he had asked to be kept in the loop. (b )(5)
From: M il ler, Chris Sent: Sat urday, Decem ber 15, 2018 11:48:08 AM To: Nieh, Ho; Franovich, M ike
Subject:
Re : CPS Submittal Status Update Yes I am available to call in from home on any day except Thursday next week. Jeremy and Billy are also available in the office next week.
From: Nieh, Ho Sent: Friday, December 14, 2018 8:06:13 PM To: Franovich, M ike; M iller, Chris
Subject:
Fwd: CPS Submittal Stat us Update Hi guys.
Can we have a chat about this next week please?
Informal discussion in the earlier AM or later PM would be fine.
Thanks, Ho Sent fro m my iPhone From: "Miller, Chr is" <Chris MiHer@nrc gov>
Subject:
Re: CPS Submittal Status Update Date: 14 December 2018 17:2 1 To: "Casey, Lauren" <Lauren Casey@nrc gov>, "Groom, Jeremy"
<Jeremy,Groom@nrc.gov>, "Dickson, Billy" <Billy,Dickson@nrc.gov>, "Franovich, Mike"
<Mike.Franovich@nrc.gov>
Cc: "Nieh, Ho" <Ho.Nieh@nrc.gov>, "Evans, Michele" <Michele.Evans@nrc.gov>,
"McDermott, Brian" <Brian McDermott@nrc gov>
I don' t believe a treatise was asked for during the enforcement conference. We should make a conscio us effort on how much staff effort to apply while at the same time trying to determine a reasonable way to evaluate any facts enclosed there in.
On: 14 December 2018 16: 12, "Casey, Lauren" <Lauren.Casey@nrc.gov> wrote:
FYI From: M itman, Jeffrey Sent: Friday, December 14, 2018 4:05 PM To: Fong, CJ <CJ.Fong@nrc gov>
Cc: Franovich, Mike <M ike.Franovjch@nrc.gov>; Casey, Lauren <Lauren.Casev@nrc gov>
Subject:
FW: CPS Subm itta l Stat us Update Accord ing to t he below ema il thread, we can expect some 2000 pages of add itional information on Clinton. This wi ll take some t ime to digest and access.
Jeff Mitman From: Sanchez Santiago, Elba Sent: Friday, December 14, 2018 3:37 PM To: Riemer, Kenneth <Kenneth.Riemer@nrc.gov>
Cc: Kozak, Laura <Laura.Kozak@ nrc.gov>; Mitman, Jeffrey <Jeffrey.M jtman@nrc.gov>
Subject:
FW: FW: CPS Subm ittal Status Update FYI From: Shelt on, Dale A:(GenCo-N uc) [mailto*Dale Shelton@exeloncorp com]
Sent: Friday, December 14, 2018 2:29 PM To: Sanchez Santiago, Elba <Elba SanchezSantjago@nrc gov>
Subject:
[Externa l_Sender) FW: CPS Submitta l Status Update From: Simpson, Patrick R.:(GenCo-Nuc)
Sent: Thursday, December 13, 2018 3:41 PM To: Gell rich, George:(GenCo-Nuc) <george gellrich@exeloncorp com>; Gullett, David M.:(GenCo-Nuc) <David Gullott@exeloncorp com>; Redd ick, Darani M :(BSC)
<Darani Redd jck@exeloncorp com>; Fewell, J Bradley B:(Exelon Generation)
<Brad ley fewell@exeloocorp com>
Cc: Nicely, Ken M.:(GenCo-Nuc) <ken njcely@exeloncorp com>; Shelton, Dale A:(GenCo-Nuc)
<Pale Shelt on@exeloocorp com>
Subject:
CPS Subm itta l Status Update We have received concurrence from all requested parties. Cover letter has been signed by Brad with letter dated for tomorrow (12/14) . Only items remaining are the administrative processi ng that wi ll occur on Friday as detailed below.
Given the size of the submittal with all attachments being over 2000 pages, we in tend to FedEx hardcopies to the RIii Regional Administrator and the NRC Document Control Desk. Hardcopies of the cover letter along with Attachments 1 and 2 will be sent FedEx to the RIii Deputy RA (Giessner),
EDO (Doa ne}, DEDO for Reactors(Johnson), Director NRR (Nieh), as well as Chris M il ler and Mike Franovich. In addition, to aid their review, Kozak and Mitman will be sent t he submittal via FedEx on CDs in a user friendly format. I have spoken with both Mitman and Kozak so t hey are expecting the packages.
Patrick This Email message and any attachment may contain information that is proprietary, legally privileged, confidential and/or subject to copyright belongi ng 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 : Millll.t....C.b To : Eraoovich Mike
Subject:
Re: HEP uncertainty, and Clinton Date: Thursday, February 14, 20 19 5:54:14 PM Attachments: imal)~
On: 14 February 20 19 16 :49, "Miller, Chris" <Chris Mi)ler@nrc i:ov> wrote:
Ha. !(b)(5)
On: 14 February 20 19 16:34, "Franovich, Mike" <Mjke Franoyich@nrc i:ov> wrote:
I am the lone holdout apparentl y. This will likely be elevated to the next level.
From: Miller, Chris Sent: Thursday, February 14, 2019 4:51 PM To: Franovich, M ike <Mike.Franovich @nrc.gov>
Subject:
Re: HEP uncertainty, and Clinton Thanks Mike. I hope we discussed changes that could be considered reasonable and in process to change. Or alternatively considered changing the process in the future to better risk inform future performance issues involving SD risk and HEP. These things aren't easy but at least our processes should be scrutable and reliable in the sense of repeatable.
I appreciate your insights chris On: 14 February 20 19 12:23, "Franovich, Mike" <Mike Franovich@nrc gov> wrote:
Hi Chris, Thanks for weighing in while out of the o ffice. l(b)(5)
(b)(5) results.
(b )(5)
My two cents, From: Miller, Chris Sent: Thursday, February 14, 2019 9:00 AM To: Franovich, Mike <Mike Franovich@nrc gov>; Dickson, Billy <Billy Dickson@nrc gov>; Felts, Russell <Russell Felts@nrc gov>
Cc: Miller, Chris <Chris Millec@nrc gov>
Subject:
FW: HEP uncertainty, and Cl inton Mike, (b)(5) chris From: Kozak, Laura Sent: Sunday, February 10, 2019 4:51 PM To: Lara, Julio <Julio.Lara@nrc.gov>
Subject:
HEP uncertainty This graph shows the results of HEP evaluations of different trained teams of analysts using different methods. This was published in a NU REG a few years ago. I share it with you to show t hat trained analysts can differ in their judgments, with neither being right or wrong. We should be looking for whether we have applied our method, documented our j ustification and considered the licensee's posit ion.
I would not be surprised if SERP members call for different/more analyst involvement or operator/ operator licensing involvement. I would resist the call for more analysis. Studies like this one show the variability among analysts and across methods.
l .OC100 0.... ----- * ~ -
. . ..... _ _ ~ -*--- --- "<> *'"' -+-ASEP lcJm 1 1 OE01 j :: 2S?(
r
- ~ - ...
I
- e -ASEP T~Jm 2
....- SPAR,tlTtam l
"~~
Ill I fh - - - sPAR*HTe,11112
- c l.OC*02 C:
Iii QI E
"tl
-~ \. "~
\
-.-ceor& IICR/ORCTCJlll l
\ \.
~ I -e- CBDT lie IICR/ORCTc.!Ol 2 iQI 1 DC03 '-*-I
\ \. .I\ --+-CBDT & HCR/ORC Tc.1m 3
&: \
I 0 .. ' - AlllCANATCJlll l l.OC-011
\' "-
- -0 ATHEANATcJm 2 95th %tile
- -<:I - Sth %ti Ir 1.0C-OS HFE2A HF[lC HFElA HFE 3A HF[l0 HFEs bV decreMina difflculty per crew data HEPs by HFE (All Methods)
Figure ES-1 Predicted mean HEPs by all HRA teams
[Note to requester: This graph is from a publicly available NUREG at https://www_nrc_gov/docs/ML 1617/ML16179A124.pdf
We can talk more if you fin d th is inte resting or helpful.
From : Helton Donald To : Bowman Gregory Cc : Aird David Subject : Clin ton SERP Prep Date: Wednesday, September 19, 2018 1:24 :29 PM Greg ,
I stopped by and saw Jeremy as we discussed. Jeremy confi rmed that he is covering tomorrow's SERP for DIRS. I highlighted the availability of the SERP training in ilearn, and Jeremy plans to take it this afternoon. We chatted briefly about the ri sk evaluation drivers (recovery, the licensee's rel iance on an execution-only HEP for diesel recovery, etc.)
(b)(5)
- Thanks, Don Don Helton Division of Inspection and Regional Support (Rotational)
Office of Nuclear Reactor Reg ulation US Nuclear Regulatory Commission (301 ) 415-1 545
From: Helton Donald To: Garmoe Alex: Bowman Gregory Subject : Re: Reactions to Clinton SERP Last Week Date: Tuesday, September 25, 2018 8:38:35 AM Thanks Alex. Will discuss during tomorrow afternoons coordination meeting with CJ , and monitor the situation... Mike is engaging early with staff about the content of the Choice letter, i(b )(5) !
Greg, I'm in Training all day, but let me know if Jeremy reaches o ut and wants a sounding board.
On: 24 September 20 18 17 :22, "Garmoe, Alex" <Alex.Garmoe@nrc.gov> wrote:
Greg and Don, (b)(5)
Passing along for situational awareness and so Greg can consider making Jeremy aware since he was our voting member at the SERP.
Thanks, Alex
From: franovjch Mike To: Casey Lauren Subject : Re: Clinton - Areas of Disagreement Date: Tuesday, February 26, 2019 1 :28:08 PM Hi Lauren, This list is fine to share with folks with a few tweaks.
(b)(5)
I will have a one-pager and options to share with the other SERP voting members sometime tomorrow morning when I get back from travel.
Much appreciated, Mike From: Casey, Lauren Sent: Tuesday, February 26, 2019 10:03:10 AM To: Franovich, M ike
Subject:
FW: Cli nton - Areas of Disagreement Good morning Mike, I'd like to distribute the areas of disagreement for Clinton at least a day prior to the follow-up SERP on Thursday so t hat all the voting members have an opportunity to review and understand them.
Please let me know if the list below adequately captures your areas of disagreement. If I don't hear back from you today, I will provide the list below to OE and Region Ill.
Thank you ,
Lauren From: Casey, Lauren Sent: Friday, February 15, 2019 10:19 AM To: Franovich, M ike <M ike.Fr anovich@nrc.gov>
Subject:
Clinton - Areas of Disagreement Hi Mike, Does this list adequately capture your areas of disagreement on Clinton?
(b)(5)
- Thanks, Lauren
From: Slomoo Be:bfts;,a To: Bnbles*Alcacaz ktsse Subje<t: RE: Action Matrix Date: Wodnosdai. Oecombor 19, 2018 4:29:44 PM (b )(5)
From: Robles-Alcaraz, Jesse Sent: Wednesday, December 19, 2018 3:10 PM To: Sigmon, Rebecca <Rebecca.Sigmon@nrc.gov>
Subject:
RE: Action Matrix Also, I added the data to a Sharepoint list available at:
http'[lfusion cc gov/nrrfJeam/djrs/ioeb/analysjs/LjstslActjon%2QMatrix%2QPata(Allltems aspx I figured we can keep it up to date every quarter. Working on the Pl data now.
From: Robles-Alcaraz, Jesse Sent: Wednesday, December 19, 2018 1:55 PM To: Sigmon, Rebecca <Rebecca s111rno @nrc iPY>
Subject:
Action Matrix I got through the Action Matrix data. I've been playing around with some graphs. Notice how column 3 basically disappeared in 2015.
(b )(5)
Jesse E. Robles U.S. Nuclear Regulalory Commission
Reac1or Systems Engineer NRR/DIRS/IOEB 301 -415 -2940 301-415-3061 (fax)
Jesse,Robles@11rc.gov
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From: Milman Jeffrey To: Kozak Laura
Subject:
RE : Clinton Date: Wednesday, February 13, 2019 4:09:26 PM Attachments: jmaaeooa 000 image004.cng A somewhat similar/related guidance point from RASP Volume 1 Section 6.4:
(b)(5)
Jeff Mitman From: Kozak, Laura Sent: Wednesday, February 13, 2019 5:02 PM To: Mitman, Jeffrey <Jeffrey.Mitman@nrc.gov>
Subject:
Clinton Jeff I was again preparing for the Clinton DBAI inspection. In reviewing the licensee PRA Summary notebook, I came across the following list of model uncertainties. Note number 15.
An accepted model uncertainty - so we can't credit ERO/don't know how in baseline PRA, but somehow we are supposed! to do it in SDP??
Laura The combined NRC-EPRI list of generic sources of Level 1 and initial Level 2 model uncertainties are as follows:
- 2. Support System Initiating Events
- 3. LOCA initiating event frequencies
- 4. Operation of equipment after battery depletion
- 6. Recirculation pump seal leakage treatment - BWRs with Isolation Condensers
- 7. Impact of containment venting on core cooling system NPSH
- 8. Core cooling success following containment failure or venting through non hard pipe vent paths (1l For specific applications, key assumptions and parameters should be examined both individually and in
logical combinations.
3-1 CL-PRA-013 REV. 5 Clinton PRA Summary Notebook
- 9. Room heatup calculations
- 10. Battery life calculations
- 12. Containment sump/ strainer performance
- 13. Impact of failure of pressure relief
- 14. Operability of equipment in beyond design basis environments
- 15. Credit for ERO
- 16. Pipe failure modes
- 17. Core melt arrest in-vessel
- 18. Thermally induced failure of hot leg/SG tubes - PWRs only
- 19. Vessel failure mode
- 20. Ex-vessel cooling of lower head
- 21. Core debris contact with containment
- 22. ISLOCA Frequency determination
From: Duncan Eric To: Alvarado Gui!loty Lydiana: Anderson Alan: Ariano Carole: Baker Randal: Bakhsh Sarah: Barclay Kevin: .6ackfil.
AUa.ri: Bartlett Bruce: Beavers James: Bell Stephen: Benjamin Jamje: Bergeon Bryan: Betancourt-Roldan Qi.ana; Biaoness Jay: Boettcher Julie: Boaedain Doni; Bonano Eugenio; Boston Brent: Bozaa John; .fuh I.bom.as.; Burger, Maureen : Buller. Rodney: Cameron Jamnes: Carrington Kenya: Casey. Colleen: Cassidy John:
Cender Laura: Chandrathil Prema: Christoffer Baruch Gau: Chyu Doris: ~ =Corujo-Sandin Jorge:
Craffey Ryan: Dahbur Alan: Daley Robert: Dalzen Jennifer: Demarshall Joseph : Dickson Billy; Do.rnk.e..
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Cassandra: Garza Michelle: Gattone Robert: Gavula James: Glessner John: Gilliam Jasmine: Gladden Karen; Note to requester: Glass Aaron: G2...IorJy; Gorski Lindsay: Gryglak Magdalena: Grzywa Mary: Haeg Lucas: Hafeez liaz; llilrl!la.
The same text in t he .!!lhD : Hansen Gregory: Hartman Thomas: Harvey Edwar<l: Harvey. Jacauelyn: Hausman Cheryl: Hausman attachment is in the ~ =Havertape Joshua: Heck Jared: Heller James: Hernandez Cammie: Hersey Deborah: Hills Dave:
email here. Holmberg Mel: Hunt Christopher: .lfil;.._fil: Jones Michael: Jonsson Dawn: Jose Benny: Kennedy Erin: ISba.o.
Nadim; Kimble Daniel; King Michael: Koester Nancy: Kozak Laura; Kranstuber Nancy: Krause Donald:
Kunowski Michael: Ku)lesa Jure: Laflamme Paul: LaFranzo Michael: Lambert Kenneth: Lara Julio: LaUin.
fu:a!lcti: Learn Matthew; Lee Peter: Licitra Carl: l.i.o.....BiJl; Linn Linda: Lipa Christine: Logaras Harral: l.illLMinQ:;
Magee Thomas: Mancuso Joseph: Martinez Christine: Martinez Nancy: Mason Larry: Mccraw Aaron:
McGowan Thomas; Meghani Viiay: Meyer Paul: Mills Daniel: Mitlyng Viktoria: Murray Robert; Myers Valerie; Nance Jim: Neurauter James: Ng Raymond: Nguyen April: Nieves Folch Luis: Norton Charles: Null Kevin; O"Brien Kenneth : O"Dowd Dennis: O"Dwyer Gerard: Ol)eanu Carmen: Orlikowski Robert: Orth Steven; Ospino Tyrone: Park Joon: Parker Bryan: Pelke Patricia: Pelke Paul: Peterson Hironori: Petrella Yance; Phillips Charles: Piccirillo Darren; Piskura Deborah: Pope Michael: Pusateri Kevin: R3 Citrixtest: Rahlf Sharj; Ray Teresa: Reeser David; Riemer Kenneth; Roach Gregory; Robbins John; Roberts Darrell: Rodriguez LiPo.eJ; Ruiz Robert: Rutkowski John: Sanchez Santiago Elba: Sanfilippo Nathan: Sargis Daniel: Scb.m ltfilli.aID: Schmidt Colleen: Seymour Jesse: Shaffer Vered: Shah Nirodh: Shaikh Atit: Shaughnessy Patrice; Sheldon Stuart: Shuaibi Mohammed: Skokowski Richard: smagacz Phillip: Smith Desiree: Smith Laura; Sotiropoulos Dina: St. Peters Courtney: Steffes Jakob: Stoedter Karla: Stone AnnMarie: Stricklin Rebecca; Strohmeyer Daniel: Sulaiman Zahid: Szwarc Dariusz: Tayloe Thomas: Tu....fu:'.arl: Tesar Daniel; Jom.czak.
Jam.my: Tran Frank: Yassos John: Velarde Vanessa: warren Geoffrey: White-Jackson Joan: Wilk Brenda; Woerner Gustave: Zectb Marjorie: Ziolkowski Michael: Zoia Charles: Zurawski Paul Subject : The Daily Morning Meeting News for February 13, 2019 Date: Wednesday. February 13. 2019 11 :21 :15 AM Attachments : DailyMorninaMeetinaNewsforJanuary9 2019.docx The Daily Morning Meeting News for February 13, 2019 Regional Duty Officer: Eric Duncan Teleconference Number: (800) 779-9565; Passcode: (b)(6)
Note: This newsletter may contain pre-decisional info. Do not distribute outside the NRC.
PREDICT/Leadership Model: Diversity in Thought - At the NRC, decision-making is enhanced when it incorporates a variety of viewpoints. For this reason, we cultivate a positive environment for the expression of diverse views, alternate approaches, critical thinking, collaborative problem-solving, unbiased evaluations, and honest feedback.
Support Issues:
DRP: End of Cycle meetings continue today; Results of a ROP Enhancement meeting held in headquarters will be shared soon and placed on the R:
Drive.
DRMA: Today is Wear Red Day with a photo planned immediately following today's 0815 meeting; Feedback on the quality of our telephone connections is being requested - please provide this feedback to Mike King or Tom Magee.
EICS: A Post-SERP (Significance Determination Enforcement Review Panel) caucus for the Clinton Emergency Diesel Generator issue is scheduled for tomorrow in the Incident Response Center (IRC) at the special time of 12:30 pm CST.
PAO: See NBC io the News Today
Plant Status BRANCH 1 5
Clinton: An Allegation Review Board (ARB) associated with ~,...(b_)_( .,.. ) __,...,.........,.......,....,--____.
for Exelon was discussed on Monday; The new NRC Leadership Model Value of Diversity in Thought (the "D" in "PREDICT") was discussed and yesterday's ARB was used as a good example of active listening and a willingness to take the time to learn about alternative ideas.
Dresden:
U2:
BRANCH 2
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BRANCH 4 D.C. Cook:
(b)(5)
Fermi: Yesterday' s ice storm made travel treacherous and delayed the opening of the resident inspector office (RIO) until the late morning; There is a high wind advisory in the area today until about noon EST; A public meeting is planned in headquarters for next i~~i;~, * * * . ITuesdayto .~~~~~ss the licen see*s ,lansJ o Point Beach: A site visit by Commissioner Caputo is planned for later this month.
A G02 Emergency Diesel Generator (EOG) surveillance is planned for today that will slightly
increase risk.
Post 8:15 Meeting Topics - Frazil Ice
From: Mitman Jeffrey To: Kozak I aura
Subject:
Alternate Treatment of EPS Recovery Date: Thursday, February 14, 2019 8:08:45 AM Attachments: imao~
(b)(5)
Jeff Mitman
Note to requester: The attachm ent to this email has been withheld in its entirety under FOIA Ex. B5 (deliberative process privilege).
From: Kozak Laura To : Lara Julio Subject : Clinton - recovery Date: Thursday, February 14 , 20 19 7 :07:00 AM Attachments: Credit for recQ'.llLry e x a m ~
Months ago , I pulled together a few examples of recovery in past SDPs, to help show that what we are doing at Clinton is consistent with what we have done in the past.
Laura
(b)(5)
(b )(5)
From: Mitman Jeffrey To : Kozak Laura Subject : Clinton Re-SERP Pre-Briefing Questions 02- 12-2019.docx Date: Thursday, February 14, 20 19 8 :10:56 AM Attachments: CH!l1onBe-SERP Pre-Briefin~ns 02- 12-2019.docx
Clinton re-SERP Pre-briefing Questions 02-17-2019 J. Mitman (b )(5)
(b)(5)
(b)(5)
From : Lara Julio To : Kozak Laura Subject : Clinton_FinalSERP_ Though ts.docx Date: Thursday, February 14, 20 19 5:04 :02 PM Attachments: Clinton FinalSERP Thought~
Feb. 14, 12019 LARA (b)(5)
Note to requester: Attachments are all non-responsive records due to clarifying From: Kozak Laura the request to exclude licensee To : Wilson George originated documents .
Subject : Clinton pictures Date: Friday, February 15, 2019 1 :16:00 PM Attachments: DSC01052.jpg osco10?3.jpg oscornzs jog osco1oz6jpg See attached
From: Gjessner John To: Kozak Laura Subject : RE: Clinton Date: Friday, February 15, 2019 10:08:00 AM Not quite. I have one issue then should be able to stop up From: Kozak, Laura Sent: Friday, February 15, 2019 10:02 AM To: Giessner, John <John.Giessner@ nrc.gov>
Subject:
RE: Clinton You available to chat about this today?
From: Giessner, John Sent: Friday, February 15, 2019 9:42 AM To: Kozak, Laura <La ura.Kozak@ nrc.gov>; La ra, Julio <Julio.Lara@ nrc.gov>
Cc: Roberts, Darrell <Darrell Roberts@nrc gov>
Subject:
RE: Clinton ok From: Kozak, Laura Sent: Friday, February 15, 2019 9:09 AM To: Lara, Julio <Julio Lara@nrc gov>
Cc: Giessner, John <John Gjessner@nrc gov>; Roberts, Darrell <Darrell,Roberts@nrc gov>
Subject:
FW: Cli nton Just FYI. George Wilson called me to learn more about the Clinton issue after I offered to talk to him one-on-one. He is coming up to speed in case the decision gets bumped to him, Darrell and Ho. Just wanted you all to know what I sent him.
Laura From: Kozak, Laura Sent: Friday, February 15, 2019 9:00 AM To: Wilson, George <George Wilson@nrc gov>
Subject:
Clinton George (b)(5)
(b)(5)
From: Kozak Laura To : Lara Julio Subject : Clinton - a few more points Date: Saturday, February 16, 2019 11 :45:25 AM (b)(5)
Laura
From : Lara Julio To : Hanna John : Kozak Laura Subject : Clinton_FinalSERP_R3_Lara.docx Date: Monday, February 25, 20 19 1:24:01 PM Attachments: Clinton FinalSERP R3 Lara.docx.
Check me pis
February 27, 2019 Clinton Preliminary White Finding Region Ill Comments - J. Lara (b )(5)
From: Mitman Jeffrey To: Kozak Laura Subject : FW: Clinton EOG case - potential path forward Date: Monday, February 25, 2019 6:23:39 AM I mportance: High Laura, in t he t hread below, M ike asked for some more sensit ivity calcs. I'm working on them and intend to get him resu lts today (Monday). I expect that the combination wil l get the results below the Green/Wh ite t hreshold but that the others two by themselves will not.
However, I'm looking for other BE t hat if I increased them by a factor of 2 wou ld keep them in the White range. Potential cand idates include IEF, depressurization and isolation HEPS, and non-recovery of electrical distribution system if offsite power is recovered late.
I'm working at home this morning while 1l(b ..._)_(6_)_ _ _ _ _ _ _ _ _ __,I please call my cel l whe n you get a chance.
Thanks.
Jeff M itman From: Fong, CJ Sent: Wednesday, February 20, 2019 6:47 AM To: M itman, Jeffrey <Jeffrey. M itman@nrc.gov>; Franovich, M ike <M ike.Fra novich@nrc.gov>
Subject:
Re: Cli nton EDG case - potential path forwa rd Thanks, Jeff.
CJ From: M itman, Jeffrey Sent: Tuesday, February 19, 2019 5:58 PM To: Franovich, M ike Cc: Fong, CJ
Subject:
RE: Clinton EDG case - potential path forward Will do.
Jeff Mitman From: Franovich, M ike Sent: Tuesday, February 19, 2019 12:24 PM To: M itman, Jeffrey <Jeffrey.Mitman@nrc.gov>
Cc: Fong, CJ <CJ.Fong@nrc.gov>
Subject:
RE: Clinton EDG case - potential path forward
Hi Jeff, Ah yes .... I was not clear which HEP for Case 1. You are correct. I was referring to the HEP for no n-recovery of EDG2 within one hour.
- Thanks, From: M itman, Jeffrey Sent: Tuesday, February 19, 2019 11:03 AM To: Franovich, M ike <M ike.Franoyich@nrc.goy>
Cc: Fong, CJ <CJ Fong@nrc gov>
Subject:
RE: Clinton EDG case - potential path forward Mike, for the Case 1 scenario, I assume that when you say you want a PSF of 5 instead of 10, you are referring to the HEP for non-recovery of EDG2 within one hour.
Am I correct?
Jeff Mitman From: Franovich, M ike Sent: Friday, February 15, 2019 4:29 PM To: M itma n, Jeffrey <Jeffrey Mitman@nrc gov>
Cc: Fong, CJ <CJ Fong@nrc gov>
Subject:
Clinton EDG case - potential path forward
- Jeff, (b)(5)
- Thanks,
From: Lambert Kenneth To: Lara Julio: Orlikowski Robert: O"Brjen Kenneth: Sanfilippo Nathan : Roberts Darren: Gjessner Jack: ~
Law:a; Hanna John Cc: Sanchez Santiago Elba; Sargis Daniel; Phillips Charles: Mancuso Joseph; St. Peters Courtney: 81'.aJ:al1o Gumoty Piaoa Subject : FW: NRR Areas of Disagreement for Clinton Follow-up SERP (EA-1 8-104)
Date: Tuesday, February 26, 2019 3:05:00 PM Attachments: PBA Areas of pjsaareement Clinton docx DIBS Areas at Pisaareement Clinton docx Attached are the NRR ORA and DIRS position papers for the Clinton follow-up SERP on Thursday.
Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission 630-810-4376 kenneth .lambert@nrc.gov From: Casey, Lauren Sent: Tuesday, February 26, 2019 2:26 PM To: M arshfield, M ark <Mark.Marshfield@nrc.gov>; Lambert, Kenneth <Kenneth.Lambert@nrc.gov>
Cc: Torres, Edgardo <edgardo.torrescollazo@ nrc.gov>
Subject:
NRR Areas of Disagreement for Clinton Follow-up SERP (EA-18-104)
Good afternoon, Attached for OE and Region Ill's distribution are NRR's areas of disagreement for discussion at Thursday's follow-up SERP.
Thank you ,
Lauren R. Casey NRR Enforcement Coordinator U.S. Nuclear Regulatory Commission 301 -415-1038
DRA Areas of DisaqreemenUDiscussion for Clinton Follow-up SERP (EA-1 8-104)
(b)(5)
DIRS Areas of Disagreement/Discussion for Clinton Follow-up SERP (EA-18-104)
(b )(5)
(b)(5)
(b)(5)
From: Lara Julio To : Kozak Laura Subject : Fw : Cl inton_FinalSERP_R3_Laraj bg.docx Date: Tuesday, February 26, 20 19 4:40:2 1 PM Attachments: Clinton FinalSERP R3 Lara jb.g.~
From: Giessner, John Sent: Tuesday, February 26, 2019 12 :21:49 PM To: Lara, Ju lio Cc: Roberts, Darrell
Subject:
Cli nto n_Fina lSERP _R3_Lara_jbg .docx Well written!
Couple comments to consider.
Jack
February 27, 2019 Clinton Preliminary White Finding Reaion Ill Comments - J . Lara (b )(5)
(b)(5)
(b)(5)
(b)(5)
From: Kozak Laura To: Lara Julio Subject : Clinton Date: Wednesday, February 27, 2019 5:15 :00 PM Attachments: Outline of Final Significance Determination Resoonse rev 1 .docx, (b)(5)
Final Significance Determination (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)
(b )(5)
(b )(5)
(b )(5) l(b)(5)
(b )(5)
(b )(5)
From : Lara Julio To : Hanna John : Kozak Laura Cc : Orlikowski Robert Subject : final SERP version - sending in later th is morning Date: Wednesday, February 27, 2019 6:21 :37 AM Attachments: Clinton FinalSERP R3.pdf
February 27, 2019 Clinton Preliminary White Finding Region Ill Comments - J . Lara (b)(5)
From: Kozak Laura To: Biemer Kenneth Subject : FW: Clinton EOG - sensitivity cases Date : Wednesday, February 27, 2019 12:23:42 PM Attachments: imao~
FYI From: Mitman, Jeffrey Sent: Monday, February 25, 2019 6:23 PM To: Franovich, Mike <Mike.Franovich@nrc.gov>
Cc: Fong, CJ <CJ.Fong@nrc.gov>; Kozak, Laura <Laura.Kozak@nrc.gov>
Subject:
RE: Clinton EDG - sensitivity cases (b)(5)
Thanks for hearing me out.
Jeff Mitman (b)(S)
(b )(5)
From: Franovich, Mike Sent: Friday, February 15, 2019 4:29 PM To: M itman, Jeffrey <Jeffrey Mjtman@nrc gov>
Cc: Fong, CJ <CJ Fong@nrc gov>
Subject:
Clinton EOG case - potential path forward Jeff,
(b)(5)
Thanks,
Note to requester: The attachment to this email has been withheld in its entirety under FOIA Ex. B5 (deliberative process privilege).
From: O"Brjen Kenneth To: franovicb Mike Subject : Fwd: Clinton EDG Air Start Issue - DRA Director"s Perspectives Date: Wednesday, February 27, 2019 3:40:14 PM Attachments: Clinton EDG Air Start Issue - DRA Director Persoective SERP One-oager - final.odf.
Outstanding effort Mike!
l...._ _ _ _ _ _ _ _ ___,IMy hat is off to you! Great, great effort!
(b)(5)
From: "Lambert, Kenneth" <Kenneth.Lambert@nrc.gov>
Subject:
FW: Clinton EDG Air Start Issue - DRA Director's Perspectives Date: 27 February 20 19 14: 19 To: "Lara, Julio" <Julio.Lara@nrc.gov>, "Orlikowski, Robert"
<Robert.Orlikowski@nrc.gov>, "O'Brien, Kenneth" <Kenneth.O'Brien@nrc.gov>,
"Sanfilippo, Nathan" <Nathan.Sanfilippo@nrc.gov>, "Roberts, Darrell"
<DarreILRoberts@nrc.gov>, "Giessner, John" <John.Gjcssner@nrc.gov>, "Kozak, Laura"
<Laura Kozak@nrc gov>, "Hanna, John" <John Hanna@nrc gov>, "Cameron, Jamnes"
<Jamnes.Cameron@nrc.gov>
Cc: "Sanchez Santiago, Elba" <Eiba.SanchezSantjago@nrc.gov>, "Sargis, Daniel"
<Daniel Sargis@nrc gov>, "Phillips, Charles" <Charles Pbillips@nrc gov>, "Mancuso, Joseph" <Joseph.Mancuso@nrc.gov>, "St. Peters, Courtney" <Courtney.St.Peters@nrc.gov>,
"Alvarado Guilloty, Diana" <Lydiana.AlvaradoGuilloty@nrc.gov>
Folks, Attached is additional information on the NRR ORA director's position on the Clinton EOG issue for tomorrows SERP Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regu latory Commission 630-810-4376 kenneth.lambert@nrc.gov From: Casey, Lauren Sent: Wednesday, February 27, 2019 2:03 PM To: M arshfield, M ark <Mark.Marshfield@nrc.gov>; Lambert, Kenneth <Kenneth.Lambert@mc.gov>
Subject:
FW: Clinton EDG Air Start Issue - ORA Director's Perspectives Additional information from ORA.
From: Franovich, M ike
Sent: Wednesday, February 27, 2019 2:56 PM To: Casey, La uren <Lauren.Casey@nrc.gov>
Subject:
Clinton EOG Air Start Issue - ORA Director's Perspectives Good Afternoon Lauren, Please find my attached perspectives on the Clinton case.
- Thanks,
(b )(5)
(b)( 5) 2
(b)( 5) 3
From: franovjch Mike To: O"Brien Kenneth Subject : RE: Clinton EOG Air Start Issue - ORA Oirector"s Perspectives Date: Wednesday, February 27, 2019 4:10 :42 PM You are too much!
Ma ny thanks for the generous, kind words.
From: O'Brien, Kenneth Sent: Wednesday, February 27, 2019 5:08 PM To: Franovich, M ike <Mike.Franovich@nrc.gov>
Subject:
Re: Clinton EDG Air Start Issue - DRA Director's Perspectives Mike In carefully reviewing your comments I was humbled by the quality and depth of your knowledge.
(b)(5)
Ken On: 27 February 2019 16:03, "Franovich, Mike" <Mike.Franovjch@nrc.gov> wrote:
Ah .. . I treasure your feedback!
From: O'Brien, Kenneth Sent: Wednesday, February 27, 2019 4:40 PM To: Franovich, M ike <M ike Franoyich@nrc gov>
Subject:
Fwd: Clinton EDG Air Start Issue - DRA Director's Perspectives Outstanding effort Mike!
l....____________IMy hat is off to you! Great, great effort!
(b)(5)
From: "Lambert, Kenneth" <Kenneth.Lambert@nrc.gov>
Subject:
FW: Clinton EOG Air Start Issue - DRA Director's Perspectives
Date: 27 February 2019 14:19 To: "Lara, Julio" < Julio Lara@nrc gov>, "Orlikowski, Robert"
<Robert.Oriikowski@nrc.gov>, "O'Brien, Kenneth" <Kcnncth.O'Bricn@nrc.gov>,
"Sanfilippo, Nathan" <Nathan.Sanfiljppo@nrc.gov>, "Roberts, Darrell"
<Darrell Roberts@nrc gov>, "Giessner, John" <John Giessner@nrc gov>, "Kozak, Laura"
<Laura.Kozak@nrc.gov>, "Hanna, John" <John.Hanna@nrc.gov>, "Cameron, Jamnes"
<Jamnes Cameron@nrc gov>
Cc: "Sanchez Santiago, Elba" <Elba.SanchezSantiago@nrc.gov>, "Sargis, Daniel"
<Daniel Sargis@nrc gov>,. "Phillips, Charles" <Charles,Pbillips@nrc gov>, "Mancuso, Joseph" <Joseph.Mancuso@nrc.gov>, "St. Peters, Courtney" <Courtney.St.Peters@nrc.gov>,
"Alvarado Guilloty, Diana" <Lydiana.AivaradoGui1Ioty@nrc.gov>
- Folks, Attached is additional information on the NRR ORA director's position on the Clinton EOG issue for tomorrows SERP Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regu latory Commission 630-810-4376 kenneth.lambert@nrc.gov From: Casey, Lauren Sent: Wednesday, February 27, 2019 2:03 PM To: M arshfield, M ark ; Lambert, Kenneth <Kenneth Lambert@nrc gov>
Subject:
FW: Cli nton EDG Ai r Start Issue - ORA Director's Perspectives Additional information from ORA.
From: Franovich, M ike Sent: Wednesday, February 27, 2019 2:56 PM To: Casey, Lauren <Lauren.Casey@nrc gov>
Subject:
Clinton EDG Air Start Issue - ORA Director's Perspectives Good Afternoon Lauren, Please find my attached perspectives on the Clinton case.
- Thanks,
From: Kozak Laura To : Miller Chris Subject : RE: Can I get the "long version " HEP analysis you mentioned?
Date: Thursday, February 28, 20 19 11 :30:00 AM Attachments: !::!EE..Iask Analvsis - SD- EPS-XHE-XM-NR10H /EDG2l Rev.2.doc EA-l8-0-10A CliJltoo_O_ut line oJ Fi nal Sianificaoce DeteJJnination 8esoonse_rev_1..do.cx, Not sure exactly what document you are referring to.
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Laura From: Miller, Chris Sent: Thursday, February 28, 2019 11 :13 AM To: Kozak, Laura <Laura.Kozak@ nrc.gov>
Subject:
Can I get the "long vers ion "HEP analysis you mentioned?
Human Failure Event (HFE) ID: SD-EPS-XHE-XM-NR01 H
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From: Giessner John To: Lara Julio Cc: Roberts Parcell Subject : RE: Clinton SERP Date: Thursday, February 28, 2019 8:38:00 AM From: Lara, Julio Sent: Thursday, February 28, 2019 8:35 AM To: Giessner, John <John.Giessner@ nrc.gov>
Cc: Roberts, Darrell <Darrell.Roberts@nrc.gov>
Subject:
FW: Cli nton SERP This thought is in Mike Franovich's paper.
He broached with me last night in our conversation.
Have not given it much thought till now From: Miller, Chris Sent: Thursday, February 28, 2019 8:07 AM To: Lara, Julio <Julio Lara@nrc gov>
Subject:
Clinton SERP Hi Julio, (b)(5) manks chris Christ opher Miller Director, Division of Inspection and Regional Support Office of Nuclear Reactor Regulation US Nuclear Regu latory Commission 301-415-1004
From: franovjch Mike To: fQnQ....Q,!; Mitman Jeffrey Cc: Kozak Laura
Subject:
RE: Table of Clinton EDG2 SDP selected sensitivity cases.docx Date: Thursday, February 28, 2019 8 :12:39 AM (b)(S) ..... Goodperspectives.!- - -
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From: Fong, CJ Sent: Thursday, Februa ry 28, 2019 8:34 AM To: M itman, Jeffrey <Jeffrey.M it ma n@nrc.gov>; Franovich, M ike <M ike.Fra novich@nrc.gov>
Cc: Koza k, La ura <Laura.Kozak@ nrc.gov>
Subject:
RE: Table of Cli nton EDG2 SDP selected sensit ivity cases.docx Mike et al, For the record, I agree with Jeff's technical position regarding uncertainty calculation. LJ** J t:,)(5)
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Respectfully, CJ
From: M itman, Jeffrey
Sent: Wednesday, February 27, 2019 6:2 1 PM To: Franovich, M ike <Mike.Franoyich@nrc.gov>
Cc: Fo ng, 0 <CJ .Fong@nrc.gov>; Kozak, Laura <Laura .Kozak@nrc.gov>
Subject:
Tab le of Cli nton EDG2 SOP se lected sensitiv ity cases.docx (b)(5)
Let me know if you have any questions.
Jeff Mitman
From: Kozak Laura To: Robbins John Subject : FW: Clinton SERP - Language from SPAR-H re additional personnel and its impacts on quantification Date: Friday, March 01, 2019 10:28:00 AM From: M itman, Jeffrey Sent: Friday, March 01, 2019 8:49 AM To: Franovich, M ike <Mike.Fr anovich@ nrc.gov>; Lara, Julio <Julio. Lara@nrc.gov>; Wilson, George
<George.Wilson@n rc.gov>; M iller, Chris <Chris.Miller @nrc.gov>
Cc: Fong, U <CJ.Fong@nrc.gov>; Kozak, Laura <Lau ra.Kozak@ nrc.gov>; Casey, Lauren
<Lauren .Casey@nrc.gov>; Dickson, Billy <Billy.Dickson@nrc.gov>; Aird, David <David.Aird@nrc.gov>;
Garmoe, Alex <Alex.Garmoe@nrc.gov>; Bowman, Gregory <Gregory.Bowma n@nrc.gov>
Subject:
Clinton SERP - La nguiage from SPAR- H re addit ional personnel and its impact s on qua ntificat ion (b )(5)
Jeff Mitman NUREG/CR-6883, "The SPAR-H Reliability Analysis M ethod" Executive Summary Page xiii "This report presents a simple HRA method for estimating the human error probabilities associated with operator and crew actions and decisions in response to initiating events at commercial U.S. nuclear power plants (NPPs)."
In addition to the above short method's applicability discussion, the document addresses "the crew" over 150 times. The takeaway from this for me is that the method is not addressing actions performed by an individual but the action of the combined operational crew. It recognizes and supplies guidance on how to quantify the reliability of that crew. In the context of our discussion regarding who would be in the EOG room troubleshooting the failure to start, I would argue that the SPAR-H method recognizes that the PRA needs to take into consideration the entire crew and not the lone individual. An additional important point is that the methodology is silent to crew size, composition , etc., and whether is includes expertise outside the operations department, e.g., maintenance and engineering.
However, there is a discussion of the TSC/EOC and its impacts, I discuss it next.
3.6 Change in Time Performance Shaping Factor (PSF)
Page 52 "Time Advantage. Having three times the amount of time it normally takes the operators to place the system in service gives the operators more time to recover from their own errors, to troubleshoot, realign misalignments, and communicate with others outside the control room, such as auxiliary equipment operators that may be required to perform local manipulations, and, during emergencies, personnel staffing, the Technical Support Center (TSC), and Emergency Operations Center (EOC)."
This citation documents SPAR-H's only reference to the TSC/EOC. It instructs the analyst to lower the fai lure probabi lity when the time available significantly exceeds the time required. This citation documents that the authors consider the impact of the availability of the TSC/EOC and factored it into the methodology via the available time PSF.
Section 5.1 Differences between At-Power and LP/SD Starting on Page 65 "In the context of nuclear power plant operations, workload and stress are often closely related. Increased wo rkload and stress were often cited in the literature as potential contributors to human error during LP/SD. The presence of a much larger staff, including less-experienced personnel at the plant, as well as. the influence of extended work periods, can play significant ro les in increasing the workload of operators. However, plant staff interviews indicate that high workload and stress, while potentially significant during LP/SD, did not appear to be at detrimental levels at the plant. rt was stated that during an outage, the size of the operations crew is expanded and the shift organization is changed to minimize the impact of the increased workload and to reduce the stress of outage of operations. These measures were cited by the staff as effective in minimizing the impact of outage operations on workload and stress. Therefore, we believe that the addition of personnel may increase organizational load, as opposed to individual load. Increased organizational load can result in unsafe acts, leading to human fa ilure events. Perhaps future research will evaluate staffing and organization factors more directly."
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From: Hanna John To: ALL.Ba Subject : Information Only : 8:15 meeting notes for March 1, 2019 Date: Friday, March 01 , 2019 10:49 :17 AM The Daily Morning Meeting News for March 1, 2019 Regional Duty Officer: John Hanna . - - -....
Teleconference Number: (800) 779-9565; Passcode: I -----+-
Note: This newsletter may contain pre-decisional info. Do not distribute outside the NRC.
PREDICT/Leadership Model: Collaboration and Teamwork Support Issues:
RA: No announcements.
DRP: Bob reminded us that there will be an agency wide presentation on Risk-Informed Decision Making. Julio and John will be presenting along with other Offices on case studies where risk was effectively used in our programs. The link to the iLearn course is below:
bttps://drupal,nrc.goy/announcements/standard/eyent/50365 To get credit in iLearn registe r in Course ID_ 464164 DRS: No announcements.
DNMS: Christine Lipa is onsite for the State of Ohio Integrated Management Performance Program (IMPEP) exit today. All indicators were found to be satisfactory.
EICS: The final SERP on Clinton EOG failure was held yesterday and finalized as a White finding/violation. Final significance determination letter to be sent to the licensee.
DRMA: The agency has been working with OPM et. al., on performance appraisal definitions of Outstanding, Excellent, Fully-Satisfactory. Look for a Yellow Announcement next week.
STATES: No announcements.
PAO: See NBC in the News Today Event Notifications: Event Notice 53903. See the LaSalle write-up below.
Part 21 : None.
Plant Status BRANCH 1 Clinton:
Dresden : downpower for scheduled maintenance LaSalle: U2: Mode 5 and Yellow shutdown risk; T ime to Boil is 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />sJ(b)(5)
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Quad Cities:
U1: At 95 percent power and in coastdown.
BRANCH 2 Davis Besse: Unit will be down powering to 95% for Trip and Throttle Valve Testing Duane Arnold: Ambulance on site.
Palisades: No issues.
Perry: I (b )(5)
BRANCH3 Braidwood: 100% no issues.
Byron: 100%. l(b)(S)
Monticello: At 86 percent power and in coastdown for a refueling outage. 3-4 inches of snow and -25F temps expected.
Prairie Island: 100%. 3-4 inches of snow and -25F temps expected. Licensee plans on
performing scheduled maintenance (approximately 1 week duration) on th e 0-5 EOG. !(b)(5) I rb )(5)
BRANCH 4 D.C. Cook:
At 82 percent power and in coastdown for a March 6th refueling outage U2: Replacement of Cell 14 of the safety-related 250 Volt CD battery went wel l and was completed within TS AOT.
Fermi: 1) downpower to 71 % for Trip and Throttle Valve Testinq & rod pattern adjustment ,l(b)(5) I (b )(5)
Point Beach : both units 100% no issues .
Other Issues - EWRA 30 for 30 starts.
Post 8:15 Meeting Topics - next week, discussion of Perry reactor trip.
From: Mitman Jeffrey To: fQnQ....Q,!; Franovicb Mike: Lara Julio: Wilson George: Miller Chris Cc: Kozak Laura: Casey Lauren : Dickson Billy: Aird David: Garmoe Alex: Bowman Gregory
Subject:
RE: Clinton SERP - Language from SPAR-H re additional personnel and its impacts on quantification Date: Friday, March 01 , 2019 4:14:26 PM Jeff Mitman From: Fong, CJ Sent: Friday, March 01, 2019 3:58 PM To: M itma n, Jeffrey <Jeffrey. M itman@nrc.gov>; Franovich, M ike <M ike.Fra novich@nrc.gov>; Lara, Ju lio <J ul io. Lara@nrc.gov>; Wi lson, George <George.Wilson@nrc.gov>; M iller, Chris
<Chris.Miller@ nrc.gov>
Cc: Kozak, La ura <Laura.Kozak@nrc.gov>; Casey, La uren <Lauren.Casey@nrc.gov>; Dickson, Bil ly
<Billy.Dickson@nrc.gov>; Aird, David <David.Ai rd @nrc.gov>; Garmoe, Alex <Alex.Garmoe@nrc.gov>;
Bowman, Gregory <Gregory.Bowma n@nrc.gov>
Subject:
RE: Clinton SERP - Language from SPAR-H re addit iona l personnel and its impacts on qua ntification
- Jeff, (b)(5)
Respectfully, CJ From: M itman, Jeffrey Sent: Friday, March 01, 2019 9:49 AM To: Franovich, M ike <Mike,Franoyich@nrc.gov>; Lara, Julio <Ju lio.Lara@nrc,gov>; Wilson, George
<George Wilsoo@orc gov>; Mi ller, Ch ris <Chris Mi ller@nrc gov>
Cc: Fong, CJ <CJ Fong@nrc gov>; Koza k, Laura <Laura Kozak@nrc.gov>; Casey, La uren
<Lauren .Casey@nrc,gov>; Dickson, Bi lly <Bil ly Dickson@nrc.gov>; Aird, David <David,Aird@nrc.gov>;
Garmoe, Alex <Alex.Garmoe@nrc,gov>; Bowman, Gregory <Gregory,Bowman@nrc.gov>
Subject:
Clinton SERP - La nguiage from SPAR- H re additional personnel and it s impacts on qua ntificat ion
(b)(5)
Jeff Mitman NUREG/CR-6883, "The SPAR-H Reliability Analysis Method" Executive Summary Page xiii "This report presents a simple HRA method for estimating the human error probabilities associated with operator and crew actions and decisi ons in response to initiating events at commercial U.S. nudear power plants (NPPs)."
In addition to the above short method's applicability discussion, the document addresses "the crew" over 150 times. The takeaway from this for me is that the method is not addressi ng actions performed by an individual but the action of the combined operational crew. It recognizes and supplies guidance on how to quantify the reliability of that crew. In the context of our discussion regarding who wou ld be in the EDG room troubleshooting the failure to start, I would argue that the SPAR-H method recognizes that the PRA needs to take into consideration the entire crew and not the lone individual. An additional important point is that the methodology is silent to crew size, composition, etc., and whether is includes expertise outside the operations department, e.g., maintenance and engineering.
However, there is a discussion of the TSC/EOC and its impacts, I discuss it next.
3.6 Change in Time Performance Shaping Factor (PSF)
Page 52 "Time Advantage. Having three times the amo unt of time it normally takes the operators to place the system in service gives the operators mo re time to recover from their own errors, to troubleshoot, realign misalignments, and communicate with others outside the control room, such as auxiliary equipment operators that may be re q uired to perform local manipulations, and, during emergencies, personnel staffing, the Tech nical Support Center (TSC), and Emergency Operations Center (EOC)."
This citation documents SPAR-H's only reference to the TSC/EOC. It instructs the analyst to lower the failure probability when the time available significantly exceeds the time required . This citation documents that the authors consider the impact of the availability of the TSC/EOC and factored it into the methodology via t he available time PSF.
Section 5.1 Differences between At-Power and LP/SD Starting on Page 65
" In the context of nuclear power plant operations, workload and stress are often closely related. Increased workload and stress were often cited in the literature as potential contributors to human error during LP/SD. The presence of a much larger staff, including less-experienced personnel at the plant, as well as the influence of extended work periods, can play significant roles in increasing the workload of operators. However, plant staff interviews indicate that high workload and stress, while potentially significant during LP/SD, did not appear to be at detrimental levels at the plant. It was stated that during an outage, the size of the operations crew is expanded and the shift organization is changed to minimize the impact of the increased workload and to reduce the stress of outage of operations . These measures were cited by the staff as effective in minimizing the impact of outage operations on workload and stress. Therefore, we believe that the addition of personnel may increase organizational load, as opposed to individual load. Increased organizational load can result in unsafe acts, leading to human failure events. Perhaps future research will evaluate staffing and organization factors more directly."
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From: Kozak Laura To: Mitman Jeffrey Subject : RE: Language from SPAR-H re additional personnel Date: Friday, March 01 , 2019 7:44:00 AM yes From: Mitman, Jeffrey Sent: Thursday, February 28, 2019 4:52 PM To: Koza k, Laura <Laura.Kozak@ nrc.gov>
Subject:
La nguage from SPAR-H re add itional personnel Laura, do you thinks it is worth distributing the below language to the SERP? The point would be to show that the formulators of the SPAR-H method contentiously considered additional personnel and made the decision to not debit or credit additional personnel during LP/SD.
Jeff Mitman NUREG/CR-6883, "The SPAR-H Reliability Analysis Method" Executive Summary Page xiii This report presents a simple HRA method for estimating the human e11'0r probabilities associated with operator and c rew actions and decisions in response to initiating events at commercial U.S. nudear power plants (NPPs).
In addit ion to the above short discussion of the methods applicabil ity, the document addresses "the crew" over 150 ti mes. The t akeaway from this is that the method is not addressing individual actions performed by an individua l but the action of the combined operational crew. It recognizes and t akes into consideration the combined re liability of that crew. In the cont ext of our discussion regarding who wou ld be in the EOG troubleshooting t he failure to start, I wou ld argue that t he SPAR-H method recognizes that that the PRA needs to take into consideration the entire crew and not the lone individual. However, the methodology is silent to crew size composition, e.g., whether is includes expert ise outside the operations department.
Section 5.1 Differences between At-Power and LP/SD Sta rt ing on Page 65 In the context of nuclear power plant operations, workload and stress are often closely related. Increased workload and stress were often cited in the literature as potential contributors to human error during LP/SD. The presence of a much larger staff, including less-experienced personnel at the plant, as well as the influence of extended work periods, can play significant roles in increasing the workload of operators. However, plant staff interviews indicate that high workload and stress, whi le potentially significant during LP/SD, did not appear to be at detrimental levels at the plant. It was stated that during an outage, the size of the operations crew is expanded and the shift organization is changed to
minimize the impact of the increased workload and to reduce the stress of outage of operations. These measures were cited by the staff as effective in minimizing the impact of outage operations on workload and stress. Therefore, we believe that the addition of personnel may increase organizational load, as opposed to individual load. Increased organizational load can result in unsafe acts, leading to human failure events. Perhaps future research will evaluate staffing and organization factors more directly.
The above SPAR-H discussion shows that the methodology's authors were well aware of the difference between at-power and shutdown conditions as to the aspect of crew size and composition .
The authors considered it during their formulation of the LP/SD differences, and in their judgment decided not to change the methodology to reflect that the plant' s staff would be different during shutdown.
Note to requester: The attachment From: Kozak Laura to this email has been withheld in its To : Mitman Jeffrey entirety under FO IA Ex. 85 Subject : Clin ton (deliberative process privilege).
Date: Monday , Ma rch 04, 20 19 10 :58 :00 AM Attachments: Outline of Final Significance De t e r m i n a f u . > ~
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Note to requester: The attachment to this email has From : Kozak Laura been withheld in its entirety To : Lara Julio Subject : FW : Clinton regulatory confe rence under FOIA Ex. B5 Date: Monday, March 04, 20 19 12 :03 :00 PM (deliberative process privilege).
Attachments: Cli!l1lfilBeguJato_ry~rence SRA notes j~cx.
Just FYI. Provided this to a wide audience prior to the regulatory conference.
Good info here, not sure all involved made the most of this information.
From: Kozak, Lau ra Sent: Thursday, Novembe r 29, 2018 3:48 PM To: West, Steven <Steven .West @nrc.gov>; Roberts, Darrell <Darre ll.Roberts@ nrc.gov>; Giess ner, Jo hn <John .Giess ner@nrc.gov>; Lo uden, Patri ck <Patrick. Louden@nrc.gov>; La ra, Juli o
<Julio.La ra@ nrc.gov>; O'Brien, Ken neth <Kenneth.O'Brien@n rc.gov>; Shua ibi, Moha mmed
<Mohammed.Sh uaib i@nrc.gov>; Riemer, Ke nneth <Kenneth.Riemer@ nrc.gov>; Stoedter, Karla
<Karla.Stoedte r@n rc.gov>; Cameron, Jamnes <Jamnes. Cameron@nrc.gov>; Franovich, M ike
<M ike .Fra novich@ nrc.gov>; Fong, CJ <CJ. Fo ng@ nrc.gov>; M itma n, Jeffrey
<Jeffrey.Mitma n@nrc.gov>; Phil li ps, Char les <Charles.Phi ll ips@ nrc .gov>; Sanchez Sant iago, Elba
<E lba.San chezSant iago@nrc.gov>; Sargis, Daniel <Dani el.Sargis@n rc.gov>
Subject:
Clin ton regu latory confere nce Jeff and I put together the attached one-page document.
The document covers what we think is new information , what we think are areas of disagreement but is not new information , and some important points to keep in mind during tomorrow's meeting.
If anyone has any questions before the conference , we will both be available . Please share this document as necessary with others for information .
Laura
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Note to requester: Attachment is a non-responsive record due From: Kozak Laura to clarifying the request to To: Lara Julio exclude licensee originated Subject : FW: Comments on Exelon presentation Date: Monday, March 04, 2019 12:04:00 PM documents.
Attachments: CPS Piv 2 PG Reg Cont Presentation /J 1-J 9-J 8)(2a} pdt More good info From: Kozak, Laura Sent: Friday, November 30, 2018 8:13 AM To: West, Steven <Steven.West@nrc.gov>; Roberts, Darrell <Darrell.Roberts@ nrc.gov>; Giessner, John <John.Giessner@nrc.gov>; Louden, Patrick <Patrick. Louden@n rc.gov>; Lara, Julio
<Ju lio.La ra@ nrc.gov>; O'Brien, Kenneth <Kenneth .O'Brien@nrc.gov>; Shuaibi, Mohammed
<Mohammed.Shua ibi@nrc.gov>; Franovich, M ike <M ike. Fran ovich@nrc.gov>; Fong, CJ
<CJ.Fong@ nrc.gov>; Stoedter, Karla <Karla.Stoedter@nrc.gov>; Cameron, Jamnes
<Jamnes.Cameron@nrc.gov>; Riemer, Kenneth <Kenneth.Riemer@nrc.gov>; Ph illips, Charles
<Charles.Phill ips@nrc.gov>; Sa nchez Santiago, Elba <Elba.San chezSantiago@nrc.gov>; Sa rgis, Daniel
<Daniel.Sa rgis@nrc.gov>; M itman, Jeffrey <Jeffrey.Mitman@nrc.gov>; Zou Iis, Anton ios
<Antonios.Zoulis@n rc.gov>; Casey, Lau ren <Lauren.Casey@ nrc.gov>
Subject:
FW: Comments on Exelon prese ntation All Jeff marked up the licensee procedure with some comments and highlighted areas of new information and points of disagreement.
See attached.
Laura From: M itman, Jeffrey Sent: Thursday, November 29, 2018 7:46 PM To: Koza k, Laura <Laura Kozak@nrc.gov>
Cc: M itman, Jeffrey <Jeffrey.Mitman@nrc gov>; Zou lis, Antonios <Antonjos Zoulis@nrc.gov>
Subject:
Comme nt s on Exelon presentation
- Laura, As promised.
Jeff Mitman
From : Kozak Laura To : Mitman Jeffrey Subject : Clinton - I edited the paragraph below slightly. Are you okay with this?
Date: Wednesday, March 06 , 2019 9:28 :16 AM (b)(5)
From: Kozak Laura To: Lara Julio Subject : Clinton discussion tomorrow Date: Wednesday, March 06, 2019 10:02:33 AM (b )(5)
Risk-informed, performance-based regulation will, at least in part, involve a shift in the NRC role from improving human reliability to one of monitoring human rel iability. Past efforts were appropriate ly pro-active (rather than performance based) because t he accident at TM! had clearly illustrated the serious deficiencies in programs to support effective and safe human performance.
The success of the human performance improvement programs allows the NRC to now take a more performance-based approach to regulatory oversight of human performance. Thus, if plant performance is acceptable (as monitored through risk-informed inspections and Pis), then the performance of plant personnel is assumed to be acceptable as wel l. That is, if risk- informed inspection and plant Pis for each cornerstone together indicate t hat plant performance 0308 is meeting the cornerstone objectives, then those findings also provide an indication of the acceptability of the associated human activities.
From: Kozak Laura To : Lara Julio Subject : Clinton Date: Wednesday, March 06, 2019 3:27:23 PM Attachments: Outline of Final Significance Determ ina t i o ~
very slight wording change in this version.
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From: Kozak Laura To : Riemer Kenneth Subject : Fw: input to Clinton final letter Date: Wednesday, March 06 , 2019 11 :25:36 AM Attachments: Outline of Final Significance D e t e r r n i n a t i o ~
From: Kozak, La ura Sent: Wednesday, March 6, 2019 11:15 AM To: La ra, Julio
Subject:
inp ut to Clinton fina l letter Please see attached for your review before forwarding to other SERP members.
Laura
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Note to requester: The attachment to this email has been withheld in its entirety under FO IA Ex. B5 (deliberative process privilege).
From : Lambert Kenneth To : Kozak Laura Subject : FW: Strategy Docs proposed for February Panels for Clinton.
Date: Wednesday, March 06, 2019 10:56:18 AM Attachments: .EA:.18-104-3 Clinton.MJM .OOf
- Laura, Please review the attached Clinton strategy form 3 and let me know if you have any comments on the remarks section of the strategy form . I believe the remarks section captures the results of th e SERP.
Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission 630-810-4376 kenneth.lambert@nrc.gov From: Mars hfie ld, Mark Sent: Tuesday, M arch 05, 2019 3:42 PM To: Lam bert, Kenn eth <Ke nneth.Lambert@n rc.gov>; Casey, Lauren <Lau ren.Casey@nrc.gov>
Subject:
Strategy Docs proposed for February Panels for Cli nton.
Please review.
- Thanks, Mark Marshfield OE/EB
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From : Kozak Laura To : Riemer Kenneth Subject : FW: Clinton changes made Date: Thursday, March 07 , 2019 11 :30:55 AM Attachments: Outline of Final Significance D e t e r m i n a t i o ~
From: Kozak, Lau ra Sent: Thursday, M arch 07, 2019 11:21 AM To: Lara, Jul io <J ul io.Lara@nrc.gov>
Subject:
Clin ton cha nges made Are sending out informally first to SERP members? I thought this was what we agreed to.
Should I send , or do you want to?
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From : Kozak Laura To : Mitman Jeffrey Subject : FW: Clinton Final Significance Determination Letter input Date: Thursday, March 07, 2019 1 :15:00 PM Attachments: Outline of Final Significance De t e r m i n a t i o ~
FYI. This version has incorporated some of Julio's initial comments.
From: Kozak, Lau ra Sent: Thursday, M arch 07, 2019 1:13 PM To: Lara, Jul io <J ul io.Lara@nrc.gov>; M ill er, Chris <Ch ri s. M ill er@ nrc .gov>; Franovich , Mike
<M ike. Fra novich@ nrc.gov>; W ilson, George <George.Wilson@nrc.gov>
Subject:
Clin ton Final Significance Det ermi nation Lett er inp ut Please see attached for your review and comment as requested at the last SERP meeting .
This document will ulti mately be the attachment to the final letter describing the assessment of the post-regulatory conference information. We are still working on the actual letter but wanted to get this out to ensure a timely review and issuance of the letter.
Please let me know if yo u have any questions.
Laura
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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 : Mitman Jeffrey Subject : Clinton cover letter Date: Friday, March 08, 20 19 1:43:00 PM Attachments: final signiru;~r letter ino\itQQQC Jeff I am working on a couple of paragraphs for the Clinton FSD cover letter. Can you help with the attached?
Thanks Laura
(b )(5)
Note to requester: The attachment to this email has been withheld in its entirety From: Kozak Laura under FO IA Ex. 85 To : Lara Julio (deliberative process Subject : Clin ton cover letter input privilege).
Date: Monday , March 11, 20 19 9:37 :00 AM Attachments: final signiru;~r letter inout rev 1.docx Comments?
(b )(5)
From: ~
Ta : ~
Stibject : RE:CltitonaM!l'lc! t1, r Da l11 : Ma!Kiay, Mardi 11,2(119 9:33::00AM All chments : ~
The philosophy behind the establishment of the thresholds for Pis and inspection findings was essentially to assume that an increase in Pl values or conditions indicated by the finding , would ,
if their root causes were uncorrected , be equivalent to accepting a de facto increase in the CDF and LERF metrics . Th is is clearer for the Pis than it is for the inspection findings , which may relate to a time-limited undesired cond ition . For such cases , the model used is that the event is ind icative of an underlying performance issue that, if uncorrected , would be expected to result in similar occurrences with the same frequency .
From: Mitman. Jeffrey Sent: Monday, March 11, 2019 9:25 AM To: Ko4ak, la ura <Laura.Koiak@nrc..gO'o'>
Subject:
RE:: Cl In ton cove-r le-tter Laura, altached are my suggested edits.
Jeff Mitman From: Kozak, Laura Sent: Friday, March OB, 2019 2:44 PM To: Mitman, Jeffrey <teffrey Mitmao@nrc goy>
Subject:
di nton cover lette r Jeff I am working on a couple of paragraphs for the Clinton FSD cover letter. Can you help with the attached ?
Thanks Lau ra
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 : Lambert Kenneth Cc : Riemer Kenneth Subject : Clinton final sig nificance determination letter Date: Tuesday, March 12, 2019 12:25:00 PM Attachments: final significance cover letter input rev 2.docx Ken See attached. This input is for the cover letter.
The input for the attachment to the letter has been sent to the SERP members for comment. We expect the comments back this week. After we address the comments , we will send the attachment to you.
Let me know if you have any questions.
Laura
(b)(5)
Note to requester: The attachment to this email has been From: Kozak Laura withheld in its entirety under FO IA To : Lara Julio Ex. B5 (deliberative process Subject : revised Clinton FSD cover letter privilege).
Date: Tuesday, March 12, 2019 7:35:00 AM Attachments: final signiru;~r letter inout rev 2.docx
(b)(5)
From: Kozak Laura To : Mitman Jeffrey Subject : Clinton Date: Wednesday, March 13, 2019 2:11 :00 PM Attachments: Outline of Final Significance De t e r m i n a t i o ~
FYI. The attached version is what I gave to Julio after incorporating CJ 's comments. Julio intends to review, reply to CJ , and then forward the input to be put in the final letter for concurrence.
I will be out of the office until next Wednesday.
Laura
Final Significance Determination (b )(5)
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From : Kozak Laura To : Lara Ju lio Cc : Riemer Ken neth Subject : Clin ton reply Date: Wednesday, March 13, 2019 2 :09:27 PM Attachments: Outline of Final Significance Determination Response rev 8.docx As we discussed, here are the changes I made based on CJ's comments. I accepted the vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
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From: Miller Chris To: fQng._C,!; Wilson George: Kozak Laura: Lara Julio: franovich Mike Subject : RE: Clinton Final Significance Determination Letter input Date: Wednesday, March 13, 2019 2:58:07 PM All ,
(b )(5) chris From: Fong, CJ Sent: Wednesday, March 13, 2019 12:49 PM To: Wilson, George <George.Wilson@nrc.gov>; Kozak, Laura <Laura.Koza k@nrc.gov>; Lara, Julio
<Ju lio.Lara@ nrc.gov>; Miller, Chris <Chris.Miller@nrc.gov>; Franovich, Mike
<M ike.Franovich@nrc.gov>
Subject:
RE: Clinton Final Significance Determination Letter input
Dear all,
(b)(5)
Respectfully, CJ From: Wilson, George Sent: Wednesday, March 13, 2019 5:38 AM To: Kozak, Laura <Laura Kozak@nrc.gov>; Lara, Julio <Julio Lara@nrc gov>; Miller, Chris
<Chris Miller@nrc gov>; Franovich, Mike <Mike franoyjch@nrc gov>
Cc: Fong, u <CJ.Fong@nrc,gov>
Subject:
RE: Clinton Final Sign ificance Determination Letter i nput
I have give n my comments to CJ Fong From: Kozak, Lau ra Sent: Thursday, March 7, 2019 2:13 PM To: Lara, Ju lio <Julio.Lara@nrc gov>; M ill er, Chris <Chris Miller@nrc gov>; Franovich, M ike
<Mike Franovicb@nrc gov>; Wilson, George <George.Wilson@nrc gov>
Subject:
Clinto n Final Sign ificance Determ ination Letter inp ut Please see attached for your review and comment as requested at the last SERP meeting.
This document will ultimately be the attachment to the final letter describing the assessment of the post-regulatory conference information . We are still working on the actual letter but wanted to get this out to ensure a timely review and issuance of the letter.
Please let me know if you have any questions.
Laura
From: Kozak Laura To: Mitman Jeffrey Subject : FW: Clinton Final Significance Determination Letter input Date: Wednesday, March 13, 2019 12:10:00 PM Attachments: Outline of Final Significance Determination Resoonse rev 7 (CJF comments\.docl(
From: Fong, CJ Sent: Wednesday, M arch 13, 2019 11:49 AM To: W ilson, George <George.Wilson@nrc.gov>; Kozak, Laura <Laura.Koza k@nrc.gov>; La ra, Julio
<Ju lio. La ra@ nrc.gov>; M il ler, Chris <Chris.Miller@nrc.gov>; Franovich, Mike
<M ike.Franovich@nrc.gov>
Subject:
RE: Clinton Final Sign ificance Determ ination Letter in put
Dear all,
(b )(5)
Respectfully, CJ From: W ilson, George Se nt: Wednesday, M arch 13, 2019 5:38 AM To: Koza k, Laura <Laura.Kozak@nrc gov>; Lara, Ju lio <Julio.Lara@nrc.gov>; M iller, Chris
<Chris.Miller@nrc.gov>; Franovich, M ike <Mike.Franovich@11rc.gov>
Cc: Fong, CJ <CJ.Fong@nrc.gov>
Subject:
RE : Clint on Final Significance Determination Letter i nput I have given my comments to C J Fong From: Kozak, Laura Sent: Thursday, March 7, 2019 2:13 PM To: Lara, Julio <Julio Lara@nrc gov>; M ille r, Chris <Chris Miller@nrc gov>; Fra novich, M ike
<M ike Franovich@nrc.gov>; W ilson, George <George.Wilson@nrc gov>
Subject:
Clinton Fi nal Significance Det ermination Lett er inp ut Please see attached for your review and comment as requested at the last SERP meeting.
This document will ultimately be the attachment to the f inal letter describing the assessment
of the post-regulatory conference information. We are still working on the actual letter but wanted to get this out to ensure a timely review and issuance of the letter.
Please let me know if you have any questions.
Laura
Final Significance Determination (b )(5)
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From: Lara Julio To: f:Qn.g._Q,!; Franovicb Mike: Miller Chris: Wilson George Cc: Kozak Laura
Subject:
FW: Clinton reply Date: Wednesday, March 13, 2019 4:36:34 PM Attachments: Outline of Final Significance Determination Response rev 8.docx All, Laura and I have reviewed the proposed edits CJ put forward.
Please review. Once we agree on document, we would finalize the draft Letter with this attachment and forward to OE for distribution/review/concurrence.
From: Kozak, Laura Sent: Wednesday, M arch 13, 2019 2:09 PM To: Lara, Julio <Julio. Lara@nrc.gov>
Cc: Riemer, Kenneth <Ken net h.Riemer@n rc.gov>
Subject:
Clinton reply As we discussed, here are the changes I made based on CJ's comments. I accepted the vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
However, (b)(5)
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From: franovicb Mike To: Miller Chris; FQng,._CJ: Wilson George: Kozak Laura: Lara Julio Subject : RE: Clinton Final Significance Determination Letter input Date: Wednesday, March 13, 2019 4:23:55 PM The themes below are consistent with my discussion with CJ this morning. That said, I support the approach.
From: M il ler, Chris Sent: Wednesday, M arch 13, 2019 3:58 PM To: Fong, CJ <CJ.Fong@nrc.gov>; Wi lson, George <George.Wilson@nrc.gov>; Kozak, Laura
<Laura.Kozak@n rc.gov>; La ra, Julio <Julio.La ra@nrc.gov>; Franovich, Mi ke
<M ike.Franovich@nrc.gov>
Subject:
RE: Clinton Final Significance Determination Let ter in put All, (b )(5) chris From: Fong, CJ Sent: Wednesday, M arch 13, 2019 12:49 PM To: W ilson, George <George.Wilson@nrc.gov>; Kozak, Lau ra <Laura.Kozak@nrc.gov>; Lara, Julio
<Ju lio.Lara@ nrc.gov>; M iller, Chris <Chris.M iller@nrc.gov>; Franovich, Mike
<M ike. Franovich@nrc.gov>
Subject:
RE: Clinton Final Significance Determination Letter in put
Dear all,
(b)(5)
Respectfully, CJ
From: Wilso n, George Sent: Wednesday, March 13, 2019 5:38 AM To: Ko zak, La ura <Laura .Kozak@nrc .gov>; Lara, Ju lio <Julio .Lara@nrc.gov>; M il ler, Chris
<Chris Miller@nrc gov>; Fran ovic h, M ike <Mike Franovicb@orc gov>
Cc: Fo ng, CJ <CJ Fong@nrc.gov>
Subject:
RE: Cl inton Fina l Significance Determ ination Letter input I have given my comme nt s to CJ Fong From: Kozak, Lau ra Sent: Th ursday, March 7, 2019 2:13 PM To: La ra, Jul io <Ju lio.Lara@nrc.gov>; M iller, Chris <Chris.Miller@nrc.gov>; Franovich, M ike
<Mike.Franovicb@orc.gov>; Wilso n, George <George.Wilson@nrc.gov>
Subject:
Clinto n Final Sign ificance Det ermination Letter inp ut Please see attached for your review and comment as requested at the last SERP meeting .
This document will ultimately be the attachment to the final letter describing the assessment of the post-regulatory conference information. We are still working on the actual letter but wanted to get this out to ensure a timely review and issuance of the letter.
Please let me know if you have any questions.
Laura
From: franovjch Mike To: Lara Julio: Elmg_.j;_~: Miller Chris: Wilson George Cc: Kozak Laura
Subject:
RE: Clinton reply Date: Wednesday, March 13, 2019 4:47:33 PM Thanks, Julio. I have no additional comments.
Looking forward to the draft final package.
From: La ra, Julio Sent: Wednesday, M arch 13, 2019 5:37 PM To: Fong, CJ <CJ. Fong@nrc.gov>; Franovich, M ike <Mi ke.Franovich@nrc.gov>; M il ler, Chris
<Chris.Miller@nrc.gov>; Wilson, George <George.Wilson@nrc.gov>
Cc: Kozak, La ura <Laura.Kozak@ nrc.gov>
Subject:
FW: Cli nton reply All, Laura and I have reviewed the proposed edits CJ put forward.
Please review. Once we agree on document, we would finalize the draft Letter with this attachment and forward to OE for distribution/review/concurrence.
From: Kozak, Laura Se nt: Wednesday, M arch 13, 2019 2:09 PM To: Lara, Julio <Julio Lara@nrc.gov>
Cc: Riemer, Kenneth <Ken net h Riemer@nrc gov>
Subject:
Clinton reply As we discussed, here are the changes I made based on CJ"s comments. I accepted the vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
(b )(5)
(b)(5)
From: Miller Chris To: Lara Julio: Elmg._CJ; f ranovich Mike: Wilson George Cc: Kozak Laura: Dickson Billy
Subject:
RE: Clinton reply Date: Thursday, March 14, 2019 11:14:11 AM Julio, I like the changes, and am good with the version you sent.
chris From: Lara, Julio Sent: Wednesday, M arch 13, 2019 5:37 PM To: Fong, CJ <CJ.Fong@ nrc.gov>; Franovich, Mi ke <Mike.Fran ovich@nrc.gov>; Miller, Chris
<Chris.Mil ler@nrc.gov>; W ilson, George <George.Wilson@nrc.gov>
Cc: Kozak, Laura <Laura. Kozak@ nrc.gov>
Subject:
FW: Cli nton reply All, Laura and I have reviewed the proposed edits CJ put forward.
Please review. Once we agree on document, we would finalize the draft Letter with this attachment and forward to OE for distribution/review/concurrence.
From: Kozak, Laura Sent: Wednesday, M arch 13, 2019 2:09 PM To: Lara, Julio <Julio Lara@nrc gov>
Cc: Riemer, Kenneth <Kenneth Biemer@nrc.gov>
Subject:
Clinton reply As we discussed, here are the changes I made based on CJ's comments. I accepted the vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
(b)(5)
(b)(5)
From: Lara Julio To: Lambert Kenneth Cc: Cameron Jamnes: Biemer Kenneth: Kozak Laura
Subject:
FW: Clinton reply Date: Thursday, March 14, 2019 12:52:30 PM Attachments: Outline of Final Significance Determination Response rev 8 .docx Importance: High
- Ken, Please incorporate the attached as an attachment/Enclosure to the Clinton Final SOP letter. I believe Laura previously sent you input paragraphs for the cover letter.
I would like to see the final letter prior to sending it out for concurrence. I can turn it around the same day. Could you forward such to me when ready.
Given where we are now, what Is a reasonable estimate for issuance?
Thanks Julio From: Lara, Julio Sent: Wednesday, M arch 13, 2019 4:37 PM To: Fong, CJ <CJ. Fong@nrc.gov>; Franovich, Mike <Mi ke.Franovich@nrc.gov>; Miller, Chris
<Chris.M il ler@nrc.gov>; Wilson, George <George.Wilson@ nrc.gov>
Cc: Koza k, La ura <Laura. Kozak @nrc.gov>
Subject:
FW: Clinton reply
- All, Laura and I have reviewed the proposed edits CJ put forward.
Please review. Once we agree on document, we would finalize the draft Letter with this attachment and forward to OE for distribution/review/concurrence.
From: Kozak, Laura Sent: Wednesday, March 13, 2019 2:09 PM To: Lara, Julio <Julio Lara@nrc gov>
Cc: Riemer, Kenneth <Kenneth.Riemer@nrc.gov>
Subject:
Clin ton reply As we discussed, here are the changes I made based on CJ's comments. I accepted the vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
(b)(5)
Final Significance Determination (b)(S)
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From : Mitman Jeffrey To : Kozak Laura Cc : Lara Julio Subject : RE: Clinton Date: Thursday, March 14, 2019 3 :16:39 PM Attachments: Outline of Final Significance Determination Response rev 8 jtm.docx Lara and Julio, I've made a couple of minor tweaks to the language for your consideration.
Thanks.
Jeff Mitman From: Kozak, Laura Sent: Wednesday, M arch 13, 2019 3: 12 PM To: M itman , Jeffrey <Jeffrey.M itman@ nrc .gov>
Subject:
Clinton FYI. The attached version is what I gave to Julio after incorporating CJ 's comments. Julio intends to review, reply to CJ , and then forward the input to be put in the final letter for concurrence.
I will be out of the office until next Wednesday.
Laura
Final Significance Determination (b )(5)
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From: Wilson George To: Miller Chris: Lara Juno: Eono.....CJ; franovich Mike Cc: Kozak Laura: Dickson Billy
Subject:
RE: Clinton reply Date: Thursday, March 14, 2019 11:25:13 AM I am also good with this version From: M il ler, Chris Sent: Thursday, March 14, 2019 12:14 PM To: Lara, Ju lio <Julio.Lara@nrc.gov>; Fong, CJ <CJ .Fong@ nrc.gov>; Franovich, Mike
<M ike.Fra novich@n rc.gov>; W ilson, George <George.Wilson@nrc.gov>
Cc: Koza k, La ura <Laura.Kozak@ nrc.gov>; Dickson, Billy <Billy.Dickson@nrc.gov>
Subject:
RE: Clinton reply
- Julio, I like the changes, and am good with the version you sent.
chris From: La ra, Julio Sent: Wednesday, M arch 13, 2019 5:37 PM To: Fong, CJ <CJ Fong@nrc gov>; Franovich, Mike <Mike Franovicb@occ gov>; Miller, Chris
<Chris Millec@orc gov>; W ilson, George <George Wilson@nrc gov>
Cc: Koza k, La ura <Laura Kozak@nrc gov>
Subject:
FW: Cli nton reply
- All, Laura and I have reviewed the proposed edits CJ put forward.
Please review. Once we agree on document, we would finalize the draft Letter with this attachment and forward to OE for distribution/review/concurrence.
From: Kozak, Laura Sent: Wednesday, M arch 13, 2019 2:09 PM To: Lara, Julio <Ju lio Lara@nrc gov>
Cc: Riemer, Kenneth <Kenneth Rjemer@nrc.gov>
Subject:
Clinton reply As we discussed, here are the changes I made based on CJ's comments. I accepted the
vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
(b)(5)
From: Lara Julio To: Lambert Kenneth Cc: Cameron Jamnes: Biemer Kenneth: Kozak Laura
Subject:
RE: Clinton reply Date: Thursday, March 14, 2019 1:33:12 PM Ok. Thanks ideally, we like to get it out NLT 3/27.
Exelon has a drop-in here on 3/28.
From: Lambert, Kenneth Sent: Thursday, March 14, 2019 1:08 PM To: Lara, Julio <Julio. Lara@nrc.gov>
Cc: Cameron, Jamnes <Ja mnes.Cameron@nrc.gov>; Riemer, Ken neth <Kenneth.Riemer @nrc.gov>;
Kozak, La ura <Laura .Kozak@ nrc.gov>
Subject:
RE: Clinton reply
- Julio, I will provide you the letter before I put into concurrence.
I would like to say that we could issue the action next week, but more realistically issue it the last week of March. Part of the complication is we need to issue an EN and need to wait until most of the concurrences are completed before issuing it.
Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission 630-810-4376 kenneth.lambert@nrc.gov From: Lara, Julio Sent: Thursday, March 14, 2019 12:52 PM To: Lambe rt, Kenneth <Kenneth Lambert@nrc gov>
Cc: Cameron, Jamnes <Jamnes Cameron@nrc gov>; Riemer, Kenneth <Kenneth Biemer@nrc gov>;
Kozak, La ura <Laura Kozak@nrc.gov>
Subject:
FW: Cli nton reply Importance: High
- Ken, Please incorporate the attached as an attachment/Enclosure to the Clinton Final SOP
letter. I believe Laura previously sent you input paragraphs for the cover letter.
I would like to see the final letter prior to sending it out for concurrence. I can turn it around the same day. Could you forward such to me when ready.
Given where we are now, what Is a reasonable estimate for issuance?
Thanks Julio From: La ra, Julio Sent: Wednesday, March 13, 2019 4:37 PM To: Fong, CJ <CJ.Fong@nrc.gov>; Franovich, Mike <Mike.Franovich@nrc.gov>; Miller, Chris
<Chris.Miller@nrc.gov>; Wi lson, George <George.Wilsoo@orc.gov>
Cc: Koza k, La ura <Laura Kozak@nrc.gov>
Subject:
FW: Clinton reply All, Laura and I have reviewed the proposed edits CJ put forward.
Please review. Once we agree on document, we would finalize the draft Letter with this attachment and forward to OE for distribution/review/concurrence.
From: Kozak, Laura Se nt: Wednesday, March 13, 2019 2:09 PM To: Lara, Julio <Julio Lara@nrc.gov>
Cc: Riemer, Kenneth <Kenneth Riemer@nrc.gov>
Subject:
Clinton reply As we discussed, here are the changes I made based on CJ's comments. I accepted the vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
{b)(5)
(b)(5)
Note to requester: The attachment to this email has been withheld in its entirety under FOIA Ex. B5 (deliberative process privilege).
From: Lara Julio To: Kozak Laura Subject : FW: Clinton final action for your review Date: Wednesday, March 20, 2019 11:48:19 AM Attachments: EA-18-104 Clinton EDG final action LARAedits.docx No.
From: La ra, Julio Sent: Friday, March 15, 2019 9:22 AM To: Lambert, Kenneth <Kenneth. Lambert@nrc.gov>
Cc: Heller, James <James.Hel ler@nrc.gov>; Orl ikowski, Robert <Robert.Orlikowski@nrc.gov>; Wilk, Brenda <Brenda.Wilk@ nrc.gov>
Subject:
Re: Cli nton fina l action for you r review Ken, Jim, please see attached edits. looks pretty good, though im confused about enclosures and edits. comments contained within. made my edits with redline/strikeout so review one-by-one.
thanks once incopt'd, forward as appropriate.
From: Lambert, Kenneth Sent: Thursday, March 14, 2019 4:29 PM To: Lara, Julio Cc: Heller, James
Subject:
Clinton fi nal action for your review Attached is the Clinton final action for your review and comments before I put it into concurrence.
We should be able to issue by or on 3/27. I will coordinate with OE to issue the EN on Thursday, 3/21.
Also, after today, I am out of the office until Tuesday.
If you want to get the action into typing tomorrow sent to Jim Clay and Jim Heller otherwise I will work on it on Tuesday morning. If Jim has any questions he can call
me.
Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission 630-810-4376 kenneth.lambert@nrc.gov From: Lara, Julio Sent: Thursday, March 14, 2019 1 :33 PM To: Lambert, Kenneth <Kenneth.Lambert@nrc.gov>
Cc: Cameron, Jamnes <Jamnes.Cameron@nrc.gov>; Riemer, Kenneth
<Kenneth.Riemer@nrc.gov>; Kozak, Laura <Laura.Kozak@nrc.gov>
Subject:
RE : Clinton reply Ok. Thanks ideally, we like to get it out NLT 3/27.
Exelon has a drop-in here on 3/28.
From: Lambert, Kenneth Sent: Thursday, March 14, 2019 1 :08 PM To: Lara, Julio <Julio.Lara@nrc.gov>
Cc: Cameron, Jamnes <Jamoes.Cameron@nrc.gov>; Riemer, Kenneth
<Kenneth.Riemer@nrc.gov>; Kozak, Laura <Laura Kozak@nrc.gov>
Subject:
RE: Clinton reply
- Julio, I will provide you the letter before I put into concurrence.
I would like to say that we could issue the action next week, but more realistically issue it the last week of March. Part of the complication is we need to issue an EN and need to wait until most of the concurrences are completed before issuing it.
Ken Ken Lambert Sr. Enforcement Specialist Region Ill U.S. Nuclear Regulatory Commission
630-810-4376 kenneth. lambert@ore.gov From: Lara, Julio Sent: Thursday, March 14, 2019 12:52 PM To: Lambert, Kenneth <Kenneth.Lambert@nrc.gov>
Cc: Cameron, Jamnes <Jamnes.Cameron@nrc.gov>; Riemer, Kenneth
<Kenneth.Riemer@nrc.gov>; Kozak, Laura <Laura.Kozak@nrc.gov>
Subject:
FW: Clinton reply Importance: High
- Ken, Please incorporate the attached as an attachment/Enclosure to the Clinton Final SOP letter. I believe Laura previously sent you input paragraphs for the cover letter.
I would like to see the final letter prior to sending it out for concurrence. I can turn it around the same day. Could you forward such to me when ready.
Given where we are now, what Is a reasonable estimate for issuance?
Thanks Julio From: Lara, Julio Sent: Wednesday, Marcil 13, 2019 4:37 PM To: Fong, CJ <CJ.Fong@nrc.gov>; Franovich, Mike <Mike.Franovich@nrc.gov>;
Miller, Chris <Cbris.Miller@nrc.gov>; Wilson, George <George.Wilson@nrc.gov>
Cc: Kozak. Laura <Laura.Kozak@nrc.gov>
Subject:
FW: Clinton reply
- All, Laura and I have reviewed the proposed edits CJ put forward.
Please review. Once we agree on document, we would finalize the draft Letter with this attachment and forward to OE for distribution/review/concurrence.
From: Kozak, Laura Sent: Wednesday, March 13, 2019 2:09 PM To: Lara, Julio d ulio.Lara@nrc.gov>
Cc: Riemer, Kenneth <Kenneth.Riemer@nrc.gov>
Subject:
Clinton reply As we discussed, here are the changes I made based on CJ's comments. I accepted the vast majority of his comments. I did make a few changes to his edits and also made a few non-significant additional edits of my own.
(b )(5)
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From: Kozak Laura To: Aird David Subject : Re: Clinton White Finding Uncertainty Date: Wednesday, March 27, 2019 7:26:46 AM Attachments: Risk Comms Clinton DG Air 9-25.ootx.
David (b)(5)
I'd be happy to talk more and participate in t his work.
Laura From: Aird, David Sent: Wednesday, March 27, 2019 7:05 AM To: Mitma n, Jeffrey; Kozak, La ura Cc: Garmoe, Alex
Subject:
Clinton White Find in g Uncerta inty Jeff and Laura, In thinking about RIDM and the use of qualitative factors, Alex and I are exploring the communication of PRA results to SERP decision makers.
(b)(5)
Also , I recall there being a one-pager that perhaps showed the model assumptions, early PRA results, etc. This may have been used for the IFRB. I should know more about this, but it was right around the time I started in DIRS and may have slipped through the cracks.
Finally, based on my research , the final determination letter should go out April 1. Let me know if that doesn't sound right.
Thanks!
1)a.v:J.. clR..fr.d..
U.S. Nuclear Regulatory Commission Reactor Operations Eng ineer NRR/DIRS/IRAB (301) 287 - 0725
INTERNAL USE ONLY
Contact:
K. Stoedter, RIii CLINTON- SDP DETAILED RISK ASSESSMENT UNAVAILABILITY OF DIVISION 2 EMERGENCY DIESEL GENERATOR The Division 2 EOG was unavailable for over 6 days.
Both divisions were unavailable for 3.5 days, while the unit was in mode 4 . The inspectors identified six separate procedures or work instructions the licensee failed to follow which led to the concurrent inoperability of both emergency diesel generators.
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The licensee concluded the finding was Green with a quantitative risk estimate of E-8. The main differences between the NRC and the licensee results are differences in human error probability estimates. The licensee's perspective is that time, resources and urgency of t he diesel recovery provide high assurance of diesel generator recovery.
Low to Substantial Moderate Safety Safety Significance Key Messages The result of the evaluation is the preliminary significance determination. The NRC's evaluation is based on reasonable and rea listic assumptions and has considered the licensee's perspectives to date. If new information is provided, it will be evaluated for impact on the significance before a final significance determination is made. (b)(5)
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From: Lara Julio To : Roberts Darren : Giessner John Cc : Sanfilippo Nathan : Shuaibi Mohammed Subject : Exe lon drop-in key messages Date: Thursday, March 28, 2019 11:09:45 AM Attachments: imaae003.png (b)(5)
Julio Lara, P.E.
Division Director Division of Reactor Projects, RIii 630-829-9600 logo-ema ils-1
[i]
From: Roberts Darrell To : Haney Catherine Cc : Mccoppin Michael: Gjessner John: Mi lly Yiktaria: Chandrathil Prema Subject : Plans for no press release on Clinton White Fl N Date: Thursday, March 28 , 2019 4 :48 :10 PM Attachments: Fw Nuclear Industry Pushing For Fewer Inspections At Plants . ms Cathy ,
(b)(5)
DJR
From: Cameron, Jamnes Sent: Thu, 28 Mar 2019 14:09:11 +0000 To: Giessn er, John; Roberts, Darrell
Subject:
Fw: Nuclear Industry Pushing For Fewer Inspections At Plants FYI From: Peralta, Juan Sent: Thursday, March 28, 2019 6:48 AM To: Furst, David; Gulla, Gera ld; Jones, David; Marench in, Thomas; Marshfield, Mark; Sreenivas, Leelavathi; Torres, Edgardo; Woods, Susanne Cc: Klukan, Brett; Kowal, Mark; Vasquez, Michael; Cameron, Jamnes; Einberg, Christian; Bowman, Gregory
Subject:
Nuclear Industry Pushing For Fewer Inspections At Plants Nuclear Industry Pushing For Fewer Inspections At Plants By Ellen Knickmeyer Associated Press, March 14, 2019 The nuclear power industry is pushing the Nuclear Regulatory Commission to cut back on inspections at nuclear power plants and throttle back what it tells the public about plant problems.
The agency, whose board is dominated by Trump appointees, is listening.
Commission staffers are weigh ing some of the industry's requests as part of a sweeping review of how the agency enforces regulations governing the country's 98 commercia lly operating nuclea r plants. Recommendations are due to the five-member NRC board in June.
Annie Caputo, a former nuclear-energy lobbyist now serving as one of four board member s appointed or reappoint ed by President Donald Trump, told an industry meeting this week that she was "open to self-assessments" by nuclear plant operators, who are proposing t hat self-reporting by operators take the place of some NRC inspections.
The Trump NRC appointees and indust ry representatives say changes in oversight are war ranted to reflect the industry's overall improved safety records and its financial difficult ies, as the operating costs of t he country's aging nuclear plants increase and affordable natural gas and solar and wind power gain in the energy market.
But the prospect of the Trump admi nistration's regulation-cutting mission reaching t he NRC alarms some independent industry w atchdogs, who say t he words "nuclear safety" and "deregulation" don't go together.
For example, "the deregulatory agenda at SEC is a significant concern as well, but it's not a nuclear power plant," said Geoffrey Fettus, a senior attorney for nuclear issues at t he Natural Resources Defense Council, referring to t he federal government's Securities Exchange Commission.
"For an industry that is increasingly under financial decline ... to take regulatory authority away from the NRC puts us on a collision course," said Paul Gunter, of the anti-nuclear group Beyond Nuclear. With what? "With a nuclear accident," Gunter said .
The industry made its requests for change in a letter delivered by t he Nuclea r Energy Institute group. A " high-priority" ask is to eliminate press releases about lower-level safety issues at plants -
meaning the kind of problems that could trigger more inspections and oversight at a plant but not constitute an emergency.
The industry group also asked that the NRC reduce the " burden of radiation-protection and emergency-preparedness inspections."
Nuclear plant operators amplified their requests at an annual meeting in the Washington, D.C, area th is week.
Scaling back disclosure of lower-l evel problems at plants is "more responsible ... than to put out a headline on the webpage to the world," sa id Greg Halnon, vice president of regulatory affa irs for Ohio-based FirstEnergy Corp., which says its fleet of nuclear and other power plants supplies 6 mill ion customers in the M idwest and Mid-Atlantic.
When the NRC makes public the problems found at a plant, utilities get " pretty rapid ca lls from t he press, SEC fi lings get impacted because of potential financial impact," Halnon said.
Requests by utilities for rate increases also can be affected, Ha lnon said.
Trump has said he wants to help both the coal and nuclear power industries. So far, it's the more politically influential coa l industry that's gotten significant action on the regulatory rollbacks that it sought from the Environment al Protection Agency and other agencies.
In January, Trump appointees to the NRC disappointed environmental groups by voting down a staff proposal that nuclear plants be requ ired to substantially - and expensively - harden themselves against major floods and other natural disasters.
The proposal was meant to be a main NRC response to the Fukushima nuclea r plant disaster after Japan's 9.0 earthquake and tsunam i in 2011. 22
Caputo, who previously worked for nuclea r plant operator Exelon Corp, told operators th is week her aim was "risk-i nformed decision-making," concentrating regulatory oversight on high-risk problems.
"We shou ldn't regulate to zero risk," sa id David Wright, a former South Carolina public-utility commissioner appointed to the NRC board last year.
"The NRC mission is reasonab le assurance of adequate protection - no more, no less," Wright said .
Tony Vegel, a Texas-based reactor safety official for the NRC, pushed back when industry executives publicly made their case for fewer NRC inspections.
"It's difficult to come across as an independent regulator and rely on self-assessment" from plants, Vegel said .
The current review, comm issioned by the new NRC panel, was looking at the inspections issues and related ones, NRC spokesman Scott Burnell said. Commissioners will decide after receiving the staff recommendations whether to adopt any of t hem, Burnell sa id.
Copyright 2019 Associated Press. All rights reserved . This material may not be published, broadcast, rewritten, or red istributed.
From: Millyoa Yiktorja To : Roberts Parcell: Giessner John Cc: Chandrathil Prema: Cameron Jamnes: Lara Julio Subject : RE: press release strategy Date: Thursday, March 28, 2019 10:42:02 AM Darrell, We were not planning to issue a press release on the Clinton White finding.
It may be useful for us to speak about the press release issue if you have time.
-Vika From: Roberts, Da rrell Se nt: Thursday, March 28, 2019 10:35 AM To: Giessner, John <John.Giessner@nrc.gov>; Mitlyng, Viktoria <Viktoria.Mitlyng@nrc.gov>
Cc: Chandrathil, Prema <Prema.Chandrathil@nrc.gov>; Cameron, Jamnes
<Jamnes.Cameron@ nrc.gov>; Lara, Ju lio <Ju lio.Lara@nrc.gov>
Subject:
RE: press release strategy (b)(5)
Thx ,
DJR From: Giessner, John Sent: Thursday, March 28, 2019 10:22 AM To: M itlyng, Viktoria <Yiktorja Mitlyog@nrc gov>
Cc: Chand rathil, Prema <Prema Chandratbil@nrc.gov>; Cameron, Jamnes
<Jamnes Cameron@nrc gov>; Lara, Ju lio <Ju lio Lara@nrc gov>; Robert s, Darrell
<Darrell.Roberts@orc.gov>
Subject:
press release strategy Vika, (b )(5)
Thanks!
Jack
From: Wilk Brenda To : Orlikowski Robert Subject : FW : EA-18-1 04 Clinton EOG final action.docx Date: Friday, March 29, 20 19 2 :37 :35 PM Attachments: EA:18~1inton EDG fi nal action.docx:
From: Olteanu, Carmen Sent: Frid ay, Ma rch 29, 2019 9:52 AM To: Wilk, Brenda <Bre nda .Wilk @nrc.gov>
Subject:
EA-18-104 Clinto n EOG fina l action .docx Please see attached.
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 April 1, 2019 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 - FINAL SIGNIFICANCE DETERMINATION OF A WHITE FINDING WITH ASSESSMENT FOLLOW-UP AND NOTICE OF VIOLATION; NRC INSPECTION REPORT NO. 05000461/2018092
Dear Mr. Hanson:
This letter provides you the final significance determination of the preliminary White finding discussed in our previous communication, dated November 6, 2018, which included Inspection Report 05000461/2018051. The preliminary finding involved an apparent violation of T itle 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and Technical Specification 3.8.2, Condition B.3, concerning the failure to follow multiple procedures regarding the emergency diesel generators (EDGs). The inspection report discussing the preliminary finding can be found in the U.S. Nuclear Regulatory Commission's (NRC's) Agencywide Documents Access and Management System (ADAMS) under Accession Number ML18311A151.
At your request, a Regulatory Conference was held on November 30, 2018, to discuss your views on this issue. A copy of the handout your staff provided at the meeting was entered into ADAMS under Accession Number ML18333A333. A NRC summary of the Regulatory Conference was entered into ADAMS under Accession Number ML18355A272. During the conference, your staff described your assessment of the significance of the finding, and the corrective actions taken to resolve it, including the root cause evaluation of the finding.
Specifically, your staff agreed with the finding and violation but disagreed with the finding's preliminary determination of a White safety significance. Your staff presented their significance determination evaluation which differed from the one performed by the NRC. During the conference, the NRC staff requested additional information that your staff provided in a letter dated December 14, 2018 (ML19023A556).
After considering the information developed during the inspection, the information provided at the regulatory conference, and the supplemental information your staff submitted on December 14, the NRC has concluded that the finding is appropriately characterized as White, a finding of low to moderate safety significance. The risk quantitative estimate represents approximately a two in a million likelihood of core damage per year. The result is largely influenced by human reliability analysis and related assumptions. While the NRC considered the finding to be greater than very low safety significance (Green), the result indicates that plant operators would be very likely to be successful in mitigating the postulated event, if it occurred.
B. Hanson 2 This was a complex shutdown significance determination. As first stated in the preliminary significance determination, mitigation of a postulated loss of offsite power event would rely completely on operator action and decision making. For 6 days, the Division 2 emergency diesel generator was not available to respond to a loss of offsite power event. For 3 of the 6 days, no emergency diesel generators were available and if a loss of offsite power had occurred, the plant would have been in a station blackout condition. Recovery of the diesel generator, recovery of offsite power, or use of other power recovery methods were available to mitigate the postulated event and were considered in the significance determination. The NRC used best estimate assumptions as described in both the preliminary and final analyses and considered Exelon's perspectives regarding plant staffing levels, operator knowledge and training, plant procedures, an d the extensive time available to mitigate the event.
The NRC performed sensitivity evaluations to understand the influence of important assumptions. The sensitivity evaluations showed a range of outcomes from very low safety significance to substantial safety significance. The sensitivity evaluations were used to confirm the best estimate outcome. Enclosure 1, to this letter, "Final Significance Determination,"
provides details of the NRC's risk significance determinat1ion.
The NRC has also determined that a violation of 10 CFR Part 50 , Appendix B, Criterion V , and Technical Specification 3.8.2, Condition B.3, was identified for the failure to follow multiple procedures involving the emergency diesel generators. The failure to follow the applicable procedures resulted in the unavailability and inoperability of the Division 2 EDG while the Division 1 EDG was already out-of-service for planned maintenance. The violation is cited in the enclosed Notice of Violation (Notice) (Enclosure 2). The circumstances surrounding the violation were described in detail in Inspection Report 05000461/2018051 . In accordance with the NRC Enforcement Policy, the Notice is considered escalated enforcement action because it is associated with a White finding.
The NRC has concluded that the information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in NRC Inspection Report 05000461 /2018051. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position.
As a result of our review of Clinton's performance, including this White finding , we have assessed Clinton Power Station to be in the Regulatory Response column of the NRC's Action Matrix, effective the third quarter of 2018. Therefore, we p lan to conduct a supplemental inspection using Inspection Procedure 95001 , "Inspection for One or Two White Inputs in a Strategic Performance Area, " when your staff has notified us of your readiness for this inspection. This inspection procedure is conducted to provide assurance that the root cause and contributing cause of risk significant performance issues are understood, the extent of condition and the extent of cause are identified, and the corrective actions are sufficient to prevent recurrence.
B. Hanson 3 You have 30 calendar days from the date of this letter to appeal the staff's determination of significance for the identified White fi nding. Such appeals will be considered to have merit only if they meet the criteria given in Inspection Manual Chapter 0609 , Attachment 2. An appeal must be sent in writing to the Regional Administrator, Region Ill, 2443 Warrenville Road ,
Su ite 210 , Lisle , IL 60532- 4352.
In accordance with 10 CFR 2.390 of the NRC's "Ru les of Practice," a copy of this letter, its enclosures, and your response , if you choose to provide one, will be made available electronically for public inspection in the NRG Public Document Room or from the NRC's document system (ADAMS) , accessible from the NRG Web site at http://www.nrc.gov/reading-rm/adams.html. If you choose to respond , to the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction .
Sincerely, IRA/
Darrell J. Roberts Regional Adm inistrator Docket No. 050-00461 License No. NPF-62
Enclosures:
- 1. Final Significance Determination
- 2. Notice of Violation cc: Distribution via LI STSERV
ML OFC RIII-EICS RIII-DRP RIII-DRP RIII-DRP OE ORA NRR RIii-ORA RIii-ORA NAME Lambert Kozak Riemer Lara Peralta 1 Franovich 2 Miller 3 Cameron Roberts DATE 3/20/19 3/21/19 3/21/19 3/21/19 3/26/19 3/25/19 3/25/19 3/26/19 3/28/19 Final Significance Determination A. Summary of Final Significance Determination At the regulatory conference on November 30, 2018, Exelon ("the licensee") discussed their perspectives on the preliminary significance determination and provided new information that the NRC had not previously considered . Other discussion topics included a recap of known areas of disagreement on assumptions for which no new information was presented. Exelon and the NRC agreed at the end of the conference that respective staff members would have a separate discussion to specify the new information that needed to be submitted for consideration in the significance determination. On December 4, 2018, the NRC staff held a conference call with Exelon to discuss five areas of new supporting information: battery life, recovery of the diesel generator/declaration of extended loss of AC power (ELAP), isolation of shutdown cooling, pressure control without injection, and the Division 3 to Division 2 cross-tie.
The NRC had also asked several questions during the conference. These questions were also communicated during the December 4 phone call. Exelon submitted the new information including answers to the NRC's questions from the regulatory conference, and a white paper documenting their positions discussed at the conference in a letter dated December 14, 2018 (ML19023A556).
The NRC considered EGC's perspectives and new information contained in the December 14th letter. This new information reduced the NRC's best estimate of the delta CDF associated with the finding from a preliminary estimate of 3.8E-6 per year to a range of 2.2E-6 per year to 1.4E-6 per year. Additional modeling of battery life, isolation of shutdown cooling and pressure control without injection lowered the delta CDF to 2.2E-6 per year. Further consideration of EDG recovery lowered the delta CDF to 1.4E-6 per year. Therefore, although the estimated risk was reduced, the final significance was determined to be White, a finding of low to moderate safety significance.
The new information led to changes to the event tree (ET) structure used to quantify the risk.
This ET is shown in Figure 1 below. The top two dominant core damage sequences were Sequences 18 and 37. Sequence 18 includes: LOOP initiates, failure of the emergency diesel generators (EDG), failure to recover either of the two EDGs and offsite power, successful ELAP diagnosis, successful early reactor depressurization, failure of low pressure injection (including FLEX), failure of high pressure injection, and failure of the Division 3 to Division to cross-tie.
Sequence 37 includes: LOOP initiates, failure of the EDG, failure to recover either of the two EDGs and offsite power, failure to diagnose ELAP, successful early reactor depressurization, failure of high pressure injection, failure to perform the cross-tie.
After considering the information provided by Exelon, the NRC staff made changes to the detailed risk evaluation regarding recovery of the diesel generator, battery life, the isolation of the shutdown cooling and pr,essure control without injection. The NRC also modified the event tree to model declaration of ELAP and entry into FLEX strategies vs. remaining in the station blackout procedure.
Section B of this attachment discusses in detail the NRC's consideration of the new information provided by Exelon. Section C provides a table similar to Exelon's table of "Key Points of Disagreement" provided at the regulatory conference that summarizes NRC's final view on these points.
Enclosure 1
This was a complex shutdown significance determination. As stated in the preliminary significance determination, successful mitigation of a loss of offsite power event in the degraded plant condition that existed would depend heavily on operator action and decision making involving the interaction of various recovery strategies. Consistent with Inspection Manual Chapter (IMC) 0609 Attachment 1 "Significance and Enforcement Panel Review Process" the NRC staff performed sensitivity studies to understand the influence of important assumptions.
The sensitivity evaluations indicated a range of outcomes from very low safety significance to substantial safety significance. The sensitivity evaluations were used to confirm the best estimate outcome.
B. Consideration of EGC's new information provided in the regulatory conference and in the follow-up submittal on December 14, 2018 During the development of the preliminary significance determination, the NRC staff routinely communicated with Exelon staff and considered a sizable amount of licensee information, including Exelon's risk evaluation of the finding , CL-SDP-010, "Risk Assessment - May 2018 Outage: Division 2 DG 1B Unavailable with Division 1 Bus Unavailable, Revision O," August 3, 2018. This section describes NRC's consideration of the new information and how it was evaluated.
Recovery of the Emergency Diesel Generator (EDG)
A change to the NRC's analysis was the addition of consideration of the licensee's ability to recover the EOG between 1 and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> into the SBO event. This second "4-hour" HEP was considered to have expansive time available to diagnose the cause of the EOG failure. It was determined to be dependent on the initial "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />" HEP for the failure to recover the EOG. In the 4-hour scenario, if the closed EOG starting air valves were found, a decision would be required to either continue with FLEX alignment (or the crosstie to Division 3) or to back out of the FLEX alignment (or the crosstie) an d attempt to start the Division 2 EOG. If the crew decided to back out, the operator would need to realign the plant's electrical distribution system due to changes that would be in progress from implementing either the crosstie or FLEX procedures. At the regulatory conference, the licensee emphasized rapid implementation of the cross-tie as a means to provide high assurance of recovery of AC power and suggested that it could be performed very quickly. Realigning the electrical distribution system would be necessary because either the crosstie or FLEX implementation would have begun to modify the configuration of the electrical distribution system, which would impact operation of the EOG.
This realignment is not governed by procedures or training. Modeling of EOG recovery beyond 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into an SBO event is subject to significant uncertaiinties because of the high likelihood that other AC power strategies would be pursued, which would complicate further use of the EOG as the Division 2 power source. Varying recovery of the EOG from 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> results in a range of delta CDF outcomes from 2.2E-6 per year to 1 .4E-6 per year.
Recovery of the EOG was a known area of disagreement prior to the regulatory conference.
Specifically, Exelon disagreed with the NRC's evaluation of the performance shaping factors (PSF) for the EOG recovery HEP. At the regulatory conference, Exelon discussed several positions already considered by the NRC and new information that was available for review.
The new information included training material, shift manager surveys, senior reactor operator (SRO) questionnaires, and a time validation. The licensee provided this information in writing via a letter dated December 14, 2018.
2
The written information provided by the licensee pertained to diesel generator malfunctions, including the most recent equipment operator (EO) training on the diesel generator air start flow path. It also included training on the different subsystems of the diesel generator, circuit breakers, and the auxiliary power system. Most of the material was generic and unrelated to the diesel generator air start system. The air start flow path training material provided diagrams of the air start system, however, these diagrams did not include the air receiver outlet valves that are the subject of this performance deficiency. The training covered diesel generator trips but did not specifically cover diesel generator failures, nor did it include potential repair or recovery actions. The NRC concluded that no changes were appropriate for the one-hour diesel generator operator recovery action based on the material provided .
Battery Life The NRC's preliminary risk evaluation modeled the direct current (DC) power support function as requiring battery chargers for the batteries to complete the PRA mission based on the information provided by the licensee that battery life with load shedding was approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. At the regulatory conference, Exelon discussed the results of a new battery calculation. The NRC requested, and the licensee provided the calculation in the December 14 letter. The calculation showed that the battery life was longer than 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> and that the battery could perform its' PRA function for the 24-hour PRA miss1ion time.
The NRC did not review the licensee's battery calculation in detail; however, the NRC accepted the conclusion that that the batteries could last for the PRA mission time given that the initial condition of the plant is different from the pre-existing battery calculations that assume an extended loss of AC power event occurs with the plant iniitially operating at-power.
The NRC modified the shutdown SPAR model by adding in a dependency on the batteries with a failure probability of approximately 8E-6. The impact of this change was to effectively eliminate losses of DC power from risk significance.
Declaration of ELAP The NRC reviewed information presented on declaration of ELAP at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if the diesel generator had not been recovered . Specifically, the NRC reviewed the completed surveys of Clinton shift managers and completed questionnaires for 28 SROs from other stations.
The licensee stated that ELAP would not be declared at 11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. In reviewing the Clinton shift manager surveys, the NRC found that the shift managers were not provided the NRC postulated scenario. The Clinton shift managers were provided a scenario in which the diesel generator air start valves were identified as the cause of the diesel generator failure to start at 45 minutes into a station blackout event. The NRC is not challenging the licensee's assertion that an ELAP would not be declared if the cause of the EDG failure to start was actually known to the operators at 45 minutes. The NRC had discussed this point with licensee staff extensively prior to the regulatory conference. The NRC's risk assessment is driven by the scenario where at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the problem with the EDG has not been identified, requiring the operators to decide whether to declare an ELAP.
3
A second scenario presented to the Clinton shift managers in the survey also lacked information relevant to the PRA analysis. The shift managers were presented with information that offsite power would be restored within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Although this scenario was not relevant, some of the Clinton SROs provided comments indicating that they would declare an ELAP at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if the problem with the Division 2 diesel generator had not been identified. This is the relevant PRA scenario and the responses are consistent with NRC's assumption in the risk evaluation.
The Clinton shift manager survey had a third scenario in which the diesel generator was recovered but subsequently failed for a different reason. This scenario is also not directly relevant to the NRC evaluation. However, in this scenario, the survey provided information that the technical support center (TSC) would be briefing plant personnel on performing the Division 3 cross-tie procedure and estimated that it could be completed in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The survey asked Clinton shift managers if ELAP would be declared in this scenario. The Clinton shift managers generally responded "no," ELAP would not be declared in this scenario if they had confidence in the timeline associated with the Division 3 cross-tie . An alternative scenario was provided with a timeline to implement the cross-tie that exceeded 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In the Scenario 3 alternative, Clinton shift managers indicated that ELAP would be declared.
The NRC determined that that the Clinton shift manager survey results did not provide conclusive information about whether operators would declare ELAP and implement FLEX and/or attempt to implement the Division 3 cross-tie. The surveys were conducted well after the event occurred and do not reliably represent the plant response at the time of the event. The survey question postulated the TSC providing information about planning to implement the cross-tie well before 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the time at which the TSC is generally estimated to be staffed.
Throughout the NRC's review of this finding, no pre-event information (i.e., procedures or training) indicated that the availability of the Division 3 cross-tie would provide high assurance of the restoration of AC power to Division 1 or Division 2 and should be the preferred option for power recovery rather than declaring ELAP and implementing FLEX.
Other available information also supported the NRC perspective that operators would declare ELAP and implement FLEX before attempting to implement the Division 3 crosstie. The examples below are excerpts from procedures, training, and the licensee's risk evaluation of the finding.
- The existing Loss of AC Power (CPS 4200.01) procedure requires a decision regarding ELAP at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into a station blackout (SBO) and it does not discuss the availability of the cross-tie as a means to provide "high assurance" of the restoration of power to avoid declaring ELAP. Per procedure, if ELAP is declared the Loss of AC Power procedure is exited and FLEX implementation (via CPS 4306.01) takes precedence over further efforts to recover the diesel generators or offsite power. While the cross-tie is referenced in the Loss of AC procedure, it is the very last step and would not be implemented if the procedure were exited. The cross-tie procedure (CPS 4303.01 P023) was written for extensive damage/beyond design basis events and it appears that it was not well integrated with the Loss of AC Power and FLEX procedures and training to have an overall integrated approach to extended SBO conditions.
- Cross-connecting the Division 3 diesel generator is the first option in the FLEX Recovery procedure, CPS 4306.01 P020, indicating that its' use would be attempted after FLEX phase 2 implementation, not before.
4
- Section 4 .2.4.1 of the licensee's risk evaluation (CL-SDP-010 dated August 3, 2018) states, "Given a SBO condition and failure to restore the EOG 1B, operators indicated that FLEX would be the initial system pursued for alternate RPV injection given the procedural direction in the Extended Loss of Power procedure." This comports with the NRC's risk evaluation assumptions and does not agree with the Exelon's stated position at the regulatory conference.
- Appendix C of the licensee's risk evaluation documents an HEP evaluation for implementing the cross-tie. The evaluation indicates that an ELAP is in progress at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and that the crosstie "might be the means" to determine "high assurance" that the SBO coping time would not be exceeded. The evaluation showed that it was not clear that the cross-tie capability was considered to be a method of AC power recovery that provides "high assurance" prior to the discovery of the Division 2 EOG problem and the evaluation of the risk significance of the finding.
- The NRC reviewed simulator training for an SBO event in which ELAP was declared (SE-LOR-4306-FLEX). For this at-power scenario, the high pressure core spray (HPCS) pump was unavailable but the Division 3 EOG was available. Despite the availability of the EOG during the simulator scenario, ELAP was declared and FLEX implementation was pursued, indicating that ELAP/FLEX was a preferred response. This at-power simulator training is very similar to the scenario of interest in this SOP.
- Appendix D of the licensee's risk evaluation (CL-S DP-010 dated 8/3/2018) documents many HEPs associated with FLEX actions. The licensee developed a "cognitive only" HEP for the failure to recognize the need for FLEX. The documentation indicates that ELAP is declared at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into the event based on discussions with operators and simulator observation.
The responses to the questionnaire for the 28 SROs also supported the NRC's assumption about ELAP. This questionnaire, like the CPS shift manager survey, also presented scenarios that were not relevant to the NRC evaluation because the scenario involved the successful diagnosis of the cause of the EOG failure. In the first two questions to the SROs, the valves were found in the closed position at 15 minutes and at 55 minutes, respectively. However, a third question asked about whether ELAP would be declared if the valves were discovered closed at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> into an SBO. Although the SROs were instructed to answer "yes" or "no" to the question of whether to declare ELAP for these scenarios, a number of SROs provided additional comments on the scenarios. For the third scenario, many of the SROs stated that ELAP would have been decl.ared at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This is consistent with and supports NRCs assumption regarding the declaration of ELAP and implementation of FLEX before the cross-tie.
Finally, regarding modeling recovery of the EOG, FLEX, and the cross-tie, while some actions for each of these methods can be performed in parallel, they are not independent. That is the electrical distribution system cannot be lined up for FLEX implementation and for the Division 3 to Division 2 cross-tie simultaneously because the procedures conflict.
5
Based on the above understanding, the NRC concluded that its PRA modeling approach to declaring ELAP is reasonable and realistic. However, the NRC's PRA model was modified to test the assumption that operators declare an ELAP or remain in the station blackout procedure.
The modified ET is shown in Figure 1. A new top event was added to the model as a decision point. If the decision is made to declare ELAP and enter the FLEX procedures, then the FLEX strategies are then tested. If the FLEX strategies fail, then the cross-tie is questioned.
For the revised risk model, if ELAP is not declared, the FLEX strategies are not implemented.
In this case, the risk evaluation models the use of the crosstie. If the crosstie is not successful and offsite AC power is not recovered, then core damage is assumed. FLEX is not considered further in this part of the risk model for two reasons. First, there is no procedural direction to try FLEX in the crosstie procedure. Second, if the crosstie has failed, significant issues may have occurred because of the failure. The cross-tie procedure (CPS 4303.01 P023) twice reiterates safety considerations that state in part "Steps in this procedure must be performed in order to avoid the risk of personnel injury or equipment damage." The cross-tie procedure would not be exited unless it had failed and per the caution, failure impllies damage to the electrical distribution system that is required to implement the FLEX strategies.
In summary, these changes to the NRC's PRA model to specifically consider the ELAP declaration did not have a substantive impact on the risk results.
Isolation of SDC The NRC's preliminary risk evaluation did not model the operator action to close the shutdown cooling isolation valves, similar to the licensee's risk evaluation. During the regulatory conference, Exelon stated that operators would take action to isolate shutdown cooling and that if the action was successful the time to core damage wou ld be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for all sequences, including those sequences where core damage occurs with the reactor at high pressure. The NRC asked Exelon to provide the procedure guidance and training for this operator action. The new information was provided in the December 14 letter.
Isolating shutdown cooling prevents the loss of inventory through RHR system relief valves and extends the time to core damage, allowing more time for recovery actions. If the reactor coolant system (RCS) heats up and pressurizes with the RHR system not isolated from RCS , four RHR relief valves will open as designed causing RCS leakage. CPS 3312.03, "RHR Shutdown Cooling and Fuel Pool Cooling Assist," Section 8.3 discusses recovering a loss of RHR shutdown cooling flow and clearly requires the RHR suction valves from the reactor recirculation system 1E12-F008 and 1E12-F009 valves remain open if recovery is anticipated. The NRC concluded that procedure guidance existed to isolate the RHR system if Mode 3 entry was anticipated but it alone may not have prompted operators to close the valves if recovery of shutdown cooling was anticipated. A better cue to isolate shutdown cooling was reactor heat-up and pressurization, including an alarm to alert operators to high pressure in the RHR system.
Through discussions with the licensee, the NRC learned t hat the set-point of this alarm was close to the set-point of the relief valves in the RHR system.
A second cue would occur when RCS level starts to decrease due to the open RHR relief valves. Prior to the RHR relief valves opening, as the RCS heats up, the water inventory expands causing level to increase. When the RHR relief valves open, water level will turn and begin to decrease.
6
A third cue is received when water level decreases to the Level 3 scram setpoint. In addition, at Level 3 a containment isolation signal for RHR/SDC is received.
The NRC requested training material on the operator action to isolate RHR shutdown cooling.
The licensee provided a simulator scenario for a postulated event that was much different from the scenarios evaluated here. The NRC concluded that th e training was not very relevant to the actions under in this scenario.
To incorporate this new information, the NRC modified its risk analysis by adding a new event tree (ET) top event that tested for failure to isolate the RHR/SDC system from the RCS on high reactor pressure and decreasing reactor level. The modified ET is shown in Figure 1. This top event was evaluated using a new fault tree (FT). The FT tests for all three cues discussed above.
HEPs were developed for both isolation cues. It should be noted that the HEP associated with the third and final cue, on reaching Level 3, is always set to fail as the analysts determined that there was insufficient time between receiving the cue to close the F008 valve before core uncovery occurred . Finally, dependency analysis for these HEPs was developed and incorporated into the model recovery rules as appropriate.
If the operators are successful in isolating the RHR/SDC system, then the time to core uncovery is extended from the 10 to 13-hour range to about 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> allowing more time for other mitigating actions. This 18-hour assumption is based on the following: The licensee's Gothic analysis indicates time to core uncovery (TTCU) without isolation at 10 to 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Other Gothic analyses indicate with isolation at 200F (about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after event initiation), the TTCU is about 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />. In the scenario of interest, isolation is estimated to occur about 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the first cue at about 100 psig (which occurs about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after event initiation) is between the two previous scenarios. If the isolation is unsuccessful, then time to uncovery remains in the 10 to 13-hour range.
Pressure Control The NRC's preliminary significance determination modeled operator failure to maintain the reactor depressurized in conjunction with the FLEX systems injection into the RCS. At the regulatory conference, the licensee stated that operators would maintain reactor vessel pressure between 60 psig and 100 psig using safety-relief valves even if FLEX or other low pressure injection was not available. The NRC reviewed the procedures and training provided by the licensee. The NRC also reviewed the licensee's risk evaluation and human probability evaluation for this action.
The licensee provided emergency operating procedures (EOPs) and EOP support procedures, CPS 4200.01 , "Loss of AC procedure," CPS 4006.01, "Loss of Shutdown Cooling ," and CPS 4411 .09, "RPV Pressure Control Sources." In preparation of the preliminary analysis, the NRC had reviewed many procedures with respect to this operator action but had not reviewed CPS 4411.09. Neither of the two initial response procedures, "Loss of Shutdown Cooling" or "Loss of AC Power" direct the operator to maintain RCS pressure low. The "RPV Pressure Control Sources" procedure is to be used as directed by EOPs and the severe accident 7
guidelines (SAGs). For the postulated scenarios, the EOP entry condition would not be met until RPV level had decreased to Level 3, which would occur very late in the scenarios. The NRC concluded that these procedures did not provide direction to operators to maintain pressure between 60 psig and 100 psig if injection was not available to maintain inventory.
The licensee also provided information that EOP-1 for pressure control would be entered as directed by CPS 4306.01 "Extended Loss of AC power/Loss of Ultimate Heat Sink." This procedure does direct RPV pressure control in accordance with EOP-1 but is written from the perspective of an at-power extended Loss of AC power event and provides no specific direction to maintain pressure low absent an available low pressure injection source. Maintaining pressure low using EOP-1 and ELAP procedures conflicts with other licensee statements that ELAP would not be declared or that operators would pursue using RCIC by letting the reactor re-pressurize.
The licensee provided seven simulator training exercises. All the scenarios were at power events focusing on pressure control and/or depressurization. None were relevant to the shutdown station blackout scenario under review.
The licensee's risk evaluation, in (CL-SDP-010) Appendix L provided a human error probability evaluation for an operator action to manually control RPV pressure with SRVs. The NRC noted that the licensee's HEP evaluation also assumed that low pressure injection had been established and was in operation. The HEP evaluation referenced CPS 4306.01 P004, "FLEX Low Pressure RPV Make-up" which contained instructions to first set up FLEX suppression pool cooling followed by instructions to re-align the system for injection. A procedure step stated the following "May need to throttle shut 1E12-F042A(B) RHR Pump 1A(B) Test Ret[urn] to Sup[pression) Pool Valve or further reduce RPV pressure to achieve the required ~p." This step provides instruction to reduce RPV pressure after injection has been successfully implemented.
It does not provide instruction to open SRVs to maintain pressure low without injection available.
The NRC concluded that the existing procedures and training do not currently support a strategy to extend the time to core damage by maintaining pressure between 60 psig and 100 psig for an extended station blackout event in Mode 4. Nonetheless, the risk model was modified to incorporate early depressurization of the RCS prior to setting up the FLEX or other low pressure systems. See Figure 1 for the event tree. The manual reactor depressurization top event previously associated with FLEX was repurposed to test for early depressurization regardless if FLEX or other low pressure injection was being implemented. (Note in those sequences where FLEX was implemented, a second opportunity to depressurize was given if the depressurization early had failed . This second opportunity was implemented by a modification to the existing FLEX fault tree.)
HEPs were developed for both the early depressurization independent of FLEX and for the late depressurization as part of FLEX. Finally, dependency analysis for these HEPs was developed and incorporated into the model recovery rules as appropriate.
The event tree (see Figure 1) tests for successful depressurization. If depressurization is successful, then time to core uncovery is extended allowing additional time for subsequent mitigation actions.
8
Division 3 Cross-tie The NRC's preliminary determination assumed the time available to perform the cross-tie was between 5 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> based on input found in the licensee's risk evaluation (CL-SDP-010).
This activity is controlled by CPS 4303.01 P023, "Cross-Connecting Division 3 to Division 1(2)
ECCS Electrical Susses." Based on this information, the associated HEP PSF for time was set to nominal. At the regulatory conference, Exelon stated that the action was time-validated at 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and disagreed with the NRC time required assumption. Exelon provided a copy of the time validation after the regulatory conference.
The portion of CPS 4303.01 P023 providing guidance on the Division 3 to Division 2 cross-tie is found in Section 1.2. It takes 39 steps to perform in three plant locations, two of which are outside the MCR. As stated above, the NRC time required assumption was based on information in the licensee's risk evaluation (CL-SDP-010). On page 8 of that analysis, it states "Based on discussions with Operations, and a time validation study for connecting loads to the division, the cross-connect activities and the subsequent tasks to reload equipment onto the Division 2 bus can be accomplished in approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."
The NRC views the assumed 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> required in the licensee's risk analysis to be reasonable as it incorporates time to plan, perform the actual cross-tie and then restore SOC.
Based on the above re-evaluation and that fact that this cross-tie has never been performed, no changes were made to the NRC's risk evaluation.
9
C. Key Regulatory Conference Disagreements NRC New Preliminary NRC Disposition in Final Exelon Position information Determination Significance Determination provided Assumptions Air start valves No changes to the diesel found isolated within generator recovery HEP or 12 29 minutes; ELAP Yes assumption about ELAP not declared declaration. See detailed discussion in Section B Load shed recovery Modified the diesel generator proceduralized and recovery HEP. Also modeled does not complicate the additional complexity EOG recovery associated with recovering the EOG beyond 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Load shed removes control power from the EOG, potentially complicating diagnosis and recovery of the cause of the failure to start. Also, load 12 No shed, FLEX electrical alignment and/or Division 3 cross-tie alignment complicates further EOG recovery. Operator actions to back out of ELAP, FLEX, and load shedding to restore the EOG as the power source to Division 2 is not governed by procedures, is not a simple, skill of the craft task, and has no training.
ELAP not See detailed discussion in declared/FLEX Section B regarding how the 12 Yes staging only PRA model was modified to test this assumption.
EOG air start valve See detailed discussion in position easily Section B.
identified in 13 Yes knowledge-based or procedure-based mode 10
Operators No changes to diesel extensively trained generator the 13 on EOG malfunctions Yes training/experience PS F.
See detailed discussion in Section B.
Operators will close Operator action modeled with one shutdown the addition of a fault tree cooling valve per with multiple HEPs. For procedure to extend sequences in which the time to TAF from action fails, the time to TAF 2 10.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to about Yes remains the same as in the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. preliminary determination. If the action succeeds, the time to TAF is longer. See detailed discussion in Section B.
NRC inspections No changes to FLEX HEPs.
confirm that FLEX Compliance with regulatory strategy meets requirements establishes regulatory feasibility but not reliability of requirements the FLEX strategy. It does not establish or imply small human error probabilities for 14, 23,24 No PRA, which must be evaluated on a case by case basis. The HEP analysis in this evaluation does not imply that the FLEX implementation does not meet current requlatorv requirements.
FLEX trained in No changes to FLEX HEPs.
accordance with Training quality and Systematic Approach frequency is evaluated as to Training part of the HRA. The NRC agrees FLEX is trained in accordance with the Systematic Approach to 14,23, 24 No Training. However, because the FLEX actions are trained in accordance with the Systematic Approach to Training does that dictate that the associated HEPs should be small.
11
FLEX tasks similar to No changes to FLEX HEPs.
normal EO tasks The overall evolution to set-and performed in up FLEX is complex and non-adverse occurs under difficult conditions conditions. Typical H RA methods assign "nominal" PSF values for control room actions under normal lighting 14,23,24 No and environmental conditions. In comparison, actions for establishing FLEX are outside the control room under significant inferiior environmental conditions and do not warrant nominal ratinqs.
Division 3 cross-tie No changes to the Division 3 procedure is cross-tie HEP. The straightforward and procedure has 37 steps in 15 not complex No multiple plant locations, under poor lighting conditions and thus does warrant a complex ratinq . See Section B.
Division 3 cross-tie is No changes to the cross-tie time-validated at HEP. The original licensee 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> risk evaluation assumed 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> was required to perform these complex actions. This assumption 15 Yes appears more appropriate than the optimistic licensee position discussed at the regulatory conference. See Section B above for more details.
12
NOTICE OF VIOLATION Exelon Generation Company, LLC Docket No. 050-00461 Clinton Power Station License No. NPF-62 EA-18-104 During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted August 3 through September 4, 2018, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Title 1O of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V ,
"Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.
Clearance Order (C/O) 139455 instructions required the performance of CPS 3506.01 P002, "Division 2 Diesel Generator Operations," Revision 3a, in conjunction with the removal of out-of-service tags on May 9, 2018.
Procedure OP- AA- 108- 103, "Locked Equipment Program," Revision 2, Step 4.1.5, stated, "If plant conditions require a locked component to be positioned in a manner other than that indicated on the locked equipment checklist or approved procedure, then UNLOCK and REPOSITION equipment in accordance with OP- AA- 108- 101 , "Control of Equipment and System Status."
Procedure OP- AA- 108- 101, "Control of Equipment and System Status," Revision 14, Step 4.1.1.1 , stated, "Utilize an ACPS for aligning equipment outside of routine operations."
Procedure OP-AA-108-106, "Equipment Return to Service," Revision 5, Step 4.3, required that "if equipment will not be restored to the Equipment Line-up/Restoration position or the original condition, then another approved equipment status control mechanism shall be used to document equipment status (i.e., Equipment Status Tag, administrative clearance/tagout).
Procedure OP-AA-108- 101, 'Control of Equipment and System Status, ' shall be used to document abnormal equipment configuration and shall be immediately applied following equipment restoration."
Procedure OP-AA-108-106, "Equipment Return to Service," Revision 5, Step 4.4.9, which stated, "Applicable Operating procedures are complete and any equipment line-ups directed to be completed by the Operating Procedures are completed ."
Procedure OP- AA- 108- 106, "Equipment Return to Service," Revision 5, Step 4.4.14, stated, "The system/equipment has been walked down as appropriate to verify that it can be safely operated to fulfill its design function."
Procedure OP-AA-109-101, "Clearance and Tagging," Revision 12, Step 10.2.1 stated, "If a lift position is determined to be different from the normal lineup position for the present plant condition and not tracked by another C/O or procedure, then the Shift Management shall be notified and equipment tracking initiated."
Enclosure 2
Technical Specification 3.8.2, "AC Sources-Shutdown," Condition B.3, requires, in part, that an inoperable EDG be restored to an operable status immediately.
Contrary to the above, between May 9 and May 17, 2018, the licensee failed to accomplish activities affecting quality in accordance with the following procedures:
Perform CPS 3506.01 P002, "Division 2 Diesel Generator Operations," Revision 3a, in conjunction with the removal of C/O 139455 as required by the C/O restoration instructions.
Perform OP-AA-108-103, "Locked Equipment Program," Revision 2, Step 4.3, valves 1DG 160 and 1DG 161 , normally locked open, were repositioned and an ACPS was not utilized to track valve status in accordance with procedure OP-AA-108-101.
Perform OP-AA-108-106, "Equipment Return to Service," Revision 5, Step 4.3, when valves 1DG160 and 1DG161 were left in an abnormal position an approved equipment status control mechanism was not used to track equipment status.
Perform OP-AA-108-106, "Equipment Return to Service," Revision 5, Step 4.4.9, when the equipment was declared operable the applicable operating procedure CPS 3506.01 P002 had not been completed and equipment line-ups directed to be completed by the operating procedures were not completed .
Perform OP-AA-108-106, "Equipment Return to Service," Revision 5, Step 4.4.14, when the system was declared operable without being walked down.
Perform OP-AA-109-101, "Clearance and Tagging," Revision 12, Step 10.2.1, when the as left position was different from the normal lineup for the present plant condition and equipment tracking was not initiated.
Additionally, because the licensee was not aware of the Division 2 EDG's inoperability between May 14 and May 17, 2018, the licensee failed to meet Technical Specification 3.8.2.b limiting condition for operation of one DG operable and the re,quired action in Technical Specification 3.8.2, Condition B.3 was not followed.
This violation is associated with a White SDP finding.
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in NRC Inspection Report No. 05000461/2018051. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation, EA-18-104" and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington , DC 20555-0001 with a copy to the Regional Administrator, Region 111, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352, and a copy to the NRC Resident Inspector at the Clinton Power Station, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
2
If you choose to respond , your response wi ll be made available electronically for public inspection in the NRG Public Document Room or from the NRG's document system (ADAMS),
accessible from the NRG Web site at http://www.nrc.gov/read ing-rm/adams.html. Therefore, to the extent possible , the response should not include any personal privacy , proprietary, or safeguards information so that it can be made available to the Public without redaction.
In accordance with 10 GFR 19.11 , you may be requi red to post this Notice within two working days of receipt.
Dated this 1st day of April 2019 3
From: Gjessner John To : Roberts Darrell Subject : FW: Action - today- Final White Clinton Date: Friday, March 29, 2019 7:45:00 AM From: Cameron, Jamnes Sent: Friday, March 29, 2019 7:44 AM To: Giessner, John <John.Giessner@nrc.gov>
Subiect: Re : Action - todav- Final White Clinton (b )(5)
From: Giessner, John Se nt: Friday, March 29, 2019 6:48:31 AM To: Cameron, Jamnes; Lara, Julio; Orli kowski, Robert; Hanna, John; Kozak, Laura; Lambert, Ken neth Cc: Roberts, Darrell
Subject:
Action - today- Final Wh ite Clinton All (b)(5)
Jack
From: Roberts Darrell To: Shuaibi Mohammed: Gjessner John: Lara Juno: Lipa Christine: Sotiropoulos Pina: Orlikowski Robert; Sanfilippo Nathan: Pelton David Cc: O"Brien Kenneth Subject : Re: 3/27/19: Notes from the Region Il l weekly update meeting w/ Cathy Haney (acting for Dan Dorman)
Date: Friday, March 29, 2019 7:44:24 AM No action required.
Thanks, Mo.
DJR On: 28 M arch 2019 17: I 8, "Shuaibi , Mohammed" <M ohammed.Shuaibi@nrc.gov> wrote:
(b)(5)
From: Roberts, Darrell Sent: Thursday, March 28, 2019 5:22 PM To: Giessner, John <John.Giessner@nrc.gov>; Shuaibi, Mohammed <Mohammed.Shuai bi@nrc.gov>;
Lara, Julio <Julio.Lara@nrc.gov>; Lipa, Christine <Christine.Lipa@nrc.gov>; Sotiropou los, Dina
<Dina.Sotiropoulos@nrc.gov>; Orlikowski, Robert <Robert.O rlikowski@nrc.gov>; Sa nf ilippo, Nathan
<Nat han.Sa nfilippo@nrc.gov>; Pelton, David <David .Pelton@n rc.gov>
Cc: O'Brien, Kenneth <Kenneth.O'Brien@nrc.gov>
Subject:
RE : 3/27 /19: Notes from the Region Il l weekly update meeting w/ Cathy Haney (acting for Dan Dorman)
Ditto what Jack said. By the way, Exelon reps at the drop-in were not aware of the latest from industry on this.
DJR From: Giessner, John Sent: Wednesday, M arch 27, 2019 6:58 PM To: Shuaibi, Mohammed <Mohammed,Shua jbj@nrc,gov>: Roberts, Darrell
<DarreU,Roberts@nrc,gov>; La ra, Jul io <Jul io,Lara@nrc,gov>; Lipa, Christine
<Christine, Li pa@ re.gov>: Sotiropou los, Dina <Dina.Soti ropou los@nrc.gov>; Orlikowski, Robert
<Robert.Orl ikowski@nrc.gov>; Sanfili ppo, Nathan <Nathan.Sanfi li ppo@nrc.gov>; Pelton, David
<David Pelton@nrc gov>
Cc: O'Brien, Kenneth <Kenneth.O'Brien@nrc.gov>
Subject:
Re: 3/27/19: Notes from the Region Ill weekly updat e meeting w/ Cathy Haney (act ing for Dan Dorman)
I like your approach Mohammed.
Jack On: 27 March 2019 18:23, "Shuaibi, Mohammed" <Mohammed Shuaibi@nrc.gov> wrote:
(b)(5)
On: 27 March 2019 14:26, "Roberts, Darrell" <Darrel1.Roberts@nrc.gov> wrote:
- Folks, I discussed the following w ith Cathy Haney (Acting DEDR for Dan next few weeks) .
My items:
- 1. Clinton WHT finding pending issuance (planned for Monday); told her (or Margie) to be prepared for a phone call from Exelon
- 2. Three drop-ins this week (Xcel, Exelon and NEI)
- 3. All-Staff meeting this week: official roll-out of new vision!
- 4. Farewell celebration for Jared
- 6. Recent email on RIii management supporting differing views in light of RIC session comments/feedback on internal safety culture Her items:
(b)(5)
DJR From: Roberts, Darrell Sent: Thursday, Februa ry 28, 2019 10:25 AM To: Lara, Julio <Julio Lara@nrc OV>; Lipa, Christine <Christine Lipa@nrc OV>; O'Brien, Kenneth
<Ken net h.O'Brien@nrc.gov>; Shuaibi, Mohammed <Mohammed Shuajbj@nrc Ov>; Sot iropoulos, Dina <Pina Sotjropoulos@nrc gov>; Orli kowski, Robert <Robert Orljkowskj@nrc gov>; Sa nfilippo, Nathan <Nathan Sa nfiljppo@nrc gov>
Cc: Giessner, Joh n <John.Giessner@nrc.gov>
Subject:
2/ 13/ 19: Notes from t he Region Ill weekly update meeting w/ Dan Dorman
- Folks, I'm sending this two weeks late Uust found it in my draft out box).
I discussed the following w/ Dan Dorman today.
My items:
- 1. Wear Red Day for heart health
- 2. EOCs this week: long philosophical discussion during Clinton. DNP impacts (existential, grand gulf, region I examples, precedent, most involve increase oversight);
- 4. My planned drop-ins w/ Margie and Chmn on 2/ 25
- 5. Cmsr. Caputo rumored to be planning a visit to Point Beach on 2/26 (we're reaching out to OEDO to confirm)
- 7. RIC session preps continuing - we've divided topics between the four regions (contested vios, operability, backfit)
- 8. l(b)(5) I Dan items: none
Also, I plan to discuss Direct Reports Meeting results in Tuesday's leadership meeting.
- Thanks, DJR From: Roberts, Darrell Sent: Wednesday, February 06, 2019 3:29 PM To: Lara, Julio <Ju lio,Lara@nrc.gov>; Lipa, Ch ristine <Christine.Ljpa@nrc gov>; O'Brien, Kenneth
<Kenneth.O'Brien@nrc.gov>; Shuaibi, Mohammed <Mohammed.Shua ibi@nrc.gov>; Sotiropoulos, Dina <Dina,Sotiropou los@nrc gov>; Orli kow ski, Robert <Robert.Orli kowski@nrc,gov>; Sa nf ilippo, Nathan <Nathan Sanfllippo@nrc gov>
Cc: Giessner, Joh n <John,Giessner@nrc,gov>
Subject:
2/6/19: Notes from the Region Il l weekly updat e meeti ng w/ Dan Dorman and from t he AMM
- Folks, I discussed the following w/ Dan today (note the meeting did not occur the past two weeks due to absence). Also included are some key items from the Agency Mission Meeting.
My items from the Dan Dorman call:
- 1. Pending Region Ill Management temporary changes through September (Ken to 01, Mo to DRS, DRP will use actors for Deputy)
- 2. Recent weather-related impacts - gave brief summary of plant impacts and office status - the most changes in office status in recent memory
- 3. Today"s Black History month luncheon - decent turnout
- 4. (b)(5)
- 5. Region Ill Vision Statement re: Leading Change - still under development
- 6. My planned drop-ins (w/ Chairman and Margie) during the week of Marc's retirement
and Dan's Direct Reports Meeting (2/25 - 28)
- 7. RIC Session Preps Dan's items:
- 1. New ETA Mike Mccoppin will be looking to schedule the July DEDR Direct Reports Meeting in Region I.
- 2. He asked about the Clinton EOG response review status(?). I mentioned review should be finishing up, but I'd check. I also mentioned the upcoming ARB.
AMM key items (full summary coming from OEDO):
- 1. OEDO's new ETAs are in place (McCoppin is the regional ETA rep)
- 2. The next FY20 WHLDP announcement is coming in the next week. We have until mid-May to submit nominees. Recall our own Rick Skokowski and Nathan Sanfilippo are the agency's last two reps.
- 3. NEIMA act. Tim Mossman has put together a matrix of tasks (particularly the required reports) associated with the new law.
- 4. NRC's Facebook followers went from 4900 to 10,000 last week, thanks to OPA's recent efforts.
- 5. CIO Dave Nelson discussed Verizon phone/IT outages over the past two weeks.
Verizon's engineers and executives are involved. They have their arms around the various bottlenecks that contributed to the problem, and are working to resolve. The fixes may also address some previous voice quality issues we've been having w/
VTCs between HQs and regions.
- 6. Scott Moore is the Acting Office Director and John Tappert is the Acting Deputy OD for NMSS pending Cmsn's decision on new OD.
- 7. (b)(5)
- 8. Pilgrim Station will t ransition to Column 1 of the Action Matrix following completion of last CAL inspection, as well as this week's end-of-cycle meetings in Region I.
This is a significant milestone and will likely create stir with public stakeholders.
Plant is slated to permanently shut down later this year.
DJR From: Robert s, Darrell Sent: Wednesday, January 16, 2019 3:49 PM To: Lara, Julio <Ju lio Lara@nrc gov>; Lipa, Ch ristine <Christine Ljpa@nrc gov>; O'Brien, Kenneth
<Ken net h.O'Brien@nrc.gov>; Shua ibi, M ohammed <Mohammed Shua jbj@nrc gov>; Soti ropoulos,
Dina <Dina.Sotiropou!os@nrc.gov>; Orlikowski, Robert <Robert.Orlikowskj@nrc.gov>
Cc: Giessner, John <John Giessner@nrc.gov>
Subject:
RE: Region Ill weekly update meeting w/ Dan Dorman - 1/16/19
- Folks, I discussed the following w/ Dan today:
- 1. Our leadership retreat tomorrow (continuation of last week's, but w/ BCs).
- 2. Duane Arnold cessation letter pending. Told him we*re not sure of date, but that there'd be a press release.
- 3. l(b)(5)
- 4. While Cathy H. will be Acting DEDR for five weeks (after the RIC while Dan is away), Laura D. will be acting RA and Joel Munday will be acting DRA. They will likely solicit existing DDDs (agency-wide) to backfill Joel's spot.
- 5. This was ERB week, so there was no AMM today.
DJR From: Roberts, Darrell Se nt: Wednesday, January 09, 2019 4:54 PM To: Lara, Julio <Julio Lara@nrc gov>; Lipa, Christine <Christine Lipa@nrc gov>; O'Brien, Kenneth
<Kenneth.O'Brien@nrc.gov>; Shuaibi, Mohammed <Mohammed Shua ibi@nrc gov>; Sotiropoulos, Dina <Pina Sotiropou!os@nrc gov>; Orli kowski, Robert <Robert Orlikowski@nrc gov>
Cc: Roberts, Darrell <Darrell Roberts@nrc gov>; Giessner, John <John Giessner@nrc gov>
Subject:
Region Ill weekly update meeting w/ Dan Dorman - 1/9/19
- Folks, I discussed the following items w/ Dan Dorman (including the items I provided him in the email below).
From Dan:
- 1. Direct Reports Meeting in RIV last week of February - any topics? RAs please let him know (DDs/Jack if there's anything you can think of, let me know) .
- 2. After the RIC, Dan will be on international travel for 5 wks - Cathy H. will be acting DEDR.
- 3. (b)(5)
- 4. We should maintain awareness of and keep OEDO updated on FENOC's efforts to get legislation in Ohio (and PA) that would protect their plants, especially since
we're in planning stages for FY21 and later FY22 budgets, where their planned shutdowns would be affected. I've been sending him results of routine FENOC calls, but just a reiteration of the need for continued participation in those calls.
From Me:
- 1. I ave Dan a heads-u about our discussion (b )(5)
(b)(5) 2.
DJR From: Robert s, Darrell Sent: Wed nesday, January 09, 2019 1:41 PM To: Dorman, Dan <Dan.Dorman@nrc.gov>
Cc: Rivera-Varona, Aida <Aida.Rivera-Varona@nrc.gov>; Giessner, John <John.Gjessner@nrc gov>
Subject:
Region Ill items Hi Dan, Happy New Year! I hope all is well with you in HQs and that you're not having to wear two hats while Steve is still in transition.
I wanted to give you a heads-up on some items I plan to discuss during our first call today, some of which I may mention at the AMM as well.
People/Org:
- 1. See the attached announcement to RIii staff re: Acting DRS Deputy Director SESCDP assignment for Nathan Sanfilippo, which begins on Jan. 20 (for three months). We coordinated through Amanda and Trish and they said I could mention as a courtesy at the next ERB (not the AMM). I may mention it at the AMM since it has all the players and the staff is already aware.
- 2. Our other management changes are in effect or pending. We have Mohammed Shuaibi in DNMS as Acting Division Director pending Dave Pelton's arrival. To backfill Mo in DRP we have a BC (Bob Orlikowski, normally the Ops Branch chief in DRS) acting as DRIP Deputy Director. Mo will move into his permanent deputy director role in DRP when Pelton arrives in March.
- 3. Jack and I are up and running as RA/ORA with Julio in his new position as DRP Director (Louden retirement last week).
- 4. RIii senior mgmt. held a mini-retreat yesterday with the help of l(b)(S) I 1:::::: !March 17), which include development of RIii SOAPs (which support Margie's), with follow-on w) development of my vision statement for the coming year and foreseeable future (emphasizing change leadership) .
.Plants:
_ (b)(5) 1 2.
Materials:
_ (b)(5) 1 That's it for now.
Darrell
From: Kozak Laura To: Giessner John: Cameron Jamnes: Lara Julio: Orlikowski Robert: Hanna John: Lambert Kenneth Cc: Roberts Parcell
Subject:
RE: Action - today- Final White Clinton Date: Friday, March 29, 2019 7:26:00 AM From: Giessner, John Sent: Friday, March 29, 2019 6:49 AM To: Cameron, Jamnes <Jamnes.Cameron@nrc.gov>; Lara, Ju lio <J ulio.Lara@nrc.gov>; Orlikowski, Robert <Robert.Orlikowski@nrc.gov>; Hanna, John <John.Hanna@nrc.gov>; Kozak, Laura
<Laura.Kozak@nrc.gov>; Lambert, Ken neth <Kenneth.Lambert@nrc.gov>
Cc: Roberts, Darrell <Darrell.Roberts@nrc.gov>
Subject:
Action - today- Final Wh ite Clinton All, (b)(5)
Jack
Note to requester: The attachm ent to this email has been withheld in its entirety under FO IA Ex.
From : Kozak Laura B5 (deliberative process privilege).
To : stoedter Karla Subject : IFRB updates from me and Jeff Date: Thursday, July 19, 2018 12:24:00 PM Attachments: Clinton EOG Unavailability IFRB jtm2 and LCK.docm
From : Kozak Laura To : Giessner John Subject : FW: Clinton both EDGs Unavailable during Shutdown SERP Presentation Date: Thursday, September 20 , 2018 7 :41 :00 AM Attachments: Cli!llil!l.lnop Both EDGs SD SERP 09-20-18 (2).PJID.
Just FYI. Very good summary here From: Mitman, Jeffrey Sent: Wednesd ay, Se ptem ber 19, 2018 9:27 PM To: Kozak, La ura <Laura .Kozak@ nrc.gov>; Fong, CJ <CJ.Fong@ nrc.gov>; Fe lts, Russell
<Russell. Felts@ nrc .gov>; Franovich, M ike <Mike .Franovic h@nrc .gov>
Subject:
Clin ton both EDGs Unavai lable durin g Shutd own SER P Present ati on These are the slides we intend to use during Thursday's SERP. They may be modified slightly based on review comments .
Because on the limited time available, we only intend to cover Slides 3 through 7 du ri ng the meeting . These sl ides discuss:
- Conservatisms
- Non-conservatisms
- Risk results
- Sensitivity case results
- Dominant sequences The rest are intended as supplemental/background information.
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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Actual relative risk level
=:r 4
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Version Date: 07-23-2018 Pre Decisional 24
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CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5 )
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b)(S)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5 )
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )( 5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5 )
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b)(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b )(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b)(5)
CLINTON SPAR MODEL Feb 14, 2019 9:26 AM (b ) (5)
Note to requester: The first attachment to this email has been withheld in its entirety under FO IA From: Kozak Laura Ex. B5 ( deliberative process To : Helton Donald privilege). The second attachment Subject : Clin ton related documen ts Date: Tuesday, September 18, 2018 1:58:00 PM is non-responsive due to narrowing Attachments: Briefino~
the request to exclude licensee C(ediLloJ reco'll.eJV e.xamoles.do_c~ originated documents.
FYI
Clinton Division 2 EOG Significance Determination (9/20/18)
Key Messages Evaluation of the significance of the finding is in progress. The preliminary significance evaluation indicates the finding could be White.
The preliminary significance evaluation and assumptions have been discussed in detail with licensee staff.
The significance of the finding is driven by human reliability. A LOOP event would have resulted in an SBO if it had occurred during the period of time both diesel generators were unavailable. Mitigation would require either operator recovery of the DG, offsite power recovery, complicated actions to implement FLEX, or the division 3 crosstie to provide power to division 2.
SOP Both diesel generators, a portion of the Division 1 electrical system, and the HPCS pump were unavailable for 3.5 days.
Operator failure to recover the division 2 diesel generator is estimated at 2.0E-1 (successful 80% of the time). The failure probability is driven by cognitive error.
Other human actions are also influential to the evaluation.
Licensee Perspective Straightforward proceduralized response to recover the division 2 diesel generator.
Length of time available to provide mitigation response is substantial.
Multiple means exist for mitigation response.
Short exposure period Closed diesel generator air start receiver valves would be discovered within 15 minutes.
Operator failure probability is 4.6E-3 (successful 99.5% of the time). The failure probability is driven by execution errors.
Finding is of very low safety significance (E-8).
NRC Risk Analyst perspectives Multiple means exist for mitigation response (recovery, FLEX, crosstie) but they are not independent because they are all methods to recover power to division 2. FLEX and the cross-tie rely on complex operator actions and make recovery more difficult.
Diesel recovery and offsite power recovery are complicated by ELAP declaration and SBO DC load shed which are procedure-driven within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The division 2 electrical system is significantly realigned to support FLEX or the crosstie.
The time to core damage for the dominant sequence is approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. While this is longer than for some at-power sequences because of higher than normal water level and lower decay heat, it is not necessarily "substantial" given some of the complex mitigation strategies.
(b)(5)
(b)(5)
Note to requester: The attachment to From: Kozak Laura this email has been withheld in its To : Mitman Jeffrey entirety under FO IA Ex. B5 Subject : Briefing t he RA on Clinton on Thu rsday morning (deliberative process privilege).
Date: Tuesday, Sept ember 18, 2018 10:51 :00 AM Attachments: Briefin g ~
FYI. Draft briefing sheet attached.
(b)(5)
Note to requester: The attachm ents to this email have been withheld in their From: Kozak Laura entirety under FO IA Ex. B5 To : Giessner John (deliberative process Subject : Clinton privilege).
Date: Tuesday, September 18, 2018 3:09:00 PM Attachments: Briefin g ~
CrediLloJ rec011.eJV e.xamoles.do_c~
Just FYI because I know you are interested.
One page briefing sheet for meeting with West on Thursday.
2nd document is examples of other recovery examples to try to put the DG recovery in context - some will be familiar!
Laura
(b )(5)
(b )(5)
(b )(5)
Note to requester: The attachment to this email has been withheld in its entirety under From: Kozak Laura FO IA Ex. B5 (deliberative process privilege).
To : Lara Julio Subject : draft Clinton briefing Date: Tuesday, September 18, 201810:59 :00 AM Attachments: Briefing~
Just FYI
(b )(5)
Note to requester: Attachment is a non-responsive record due to clarifying the request to exclude licensee originated documents.
From: Sanchez Santiago Elba To : Sargis Daniel Subject : FW: emai l from Clinton Date: Tuesday, September 18, 2018 9:01 :02 AM Attachments: NRG CPS SDP SPAR Model Review Comments.docx.
FYI From: Kozak, Lau ra Sent: Tuesd ay, September 18, 2018 8 :34 AM To: Lo uden, Patrick <Patrick .Lou den@nrc.gov>; La ra, Ju lio <Jul io.La ra@nrc .gov>
Cc: Stoedter, Karla <Karla .Stoedter@nrc.gov>; Sanchez Santiago, Elba
<EI ba .SanchezSa ntiago@nre.gov>
Subject:
ema il from Clinton FYI - I just received a phone call and email from Clinton - the PRA staff has been provided 5 pages of comments for us to consider in our preliminary evaluation .
CPS Review Comments Of NRC's SOP In-Process SPAR Model Results The Exelon Clinton Station appreciates the opportunity to provide input to the NRC regarding the NRC in-process risk assessment associated with the CPS OG1 B Unavailability SOP. The meeting on Tuesday September 11 , 2018 at CPS where the in-process modeling was reviewed and discussed was helpful to gain insights into the current significant risk contributors, and the inputs related to those contributors. Based upon that review and discussion, Exelon Risk Management provides the following comments for consideration. It is understood that many of these comments were discussed in various levels of detail at the meeting. However, since the meeting Risk Management staff have performed additional reviews based on those discussions and our meeting notes. Specifically, since the in-process risk assessment results are notably driven by operator actions, additional review of the SPAR-H methodology used by the NRC was performed. The comments provided here are not intended to be exhaustive or a full summary of the discussions from the NRC interactions, but rather to focus on those areas that appear to be the most relevant to the dominant risk results.
Additionally, it is understood that the NRC needs to reach a finalized risk estimate in a timely fashion . Therefore, some simple model change suggestions are provided for consideration.
DG 1B Recovery The human error probability (HEP) of DG1 B recovery by operators is judged to be the most risk significant input i n the assessment and is the most straight forward of the operator actions. Therefore, particular attention is paid to this model basic event. The Exelon HEP (previously prnvided to the NRC) was estimated to be approximately 5E-03 using industry accepted methods, while the NRC initiial estimate was 0.2 based on SPAR-H. CPS does not have the NRC's HEP calculations (e.g., the SPAR-H worksheets) for detailed review, but we have attempted to reproduce the overall values to gain insights related to the potential inputs employed. Based on our review (i.e.,
postulated inputs used), the following comments are provided regarding the 0.2 value obtained by the NRC:
- The current 0.2 value is predominantly "cognitive". As such, it appears to be reflective of the following inputs in SPAR-H worksheets:
o A selection of "barely adequate time", reflective of a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time window for successful completion and a time to complete (the entire checklist) of approximately 40-45 minutes. No credit was yet in the model for continued operator recovery actions following this time.
o A selection of "High" for the performance shaping factor of Stress.
- In discussions, CPS has noted that operators will not cease DG1 B recovery efforts after one hour if the initial recovery attempts are unsuccessful. CPS needs to recover the DG even if offsite power were restored a few minutes after the postulated LOOP. Although CPS does not agree the 0.2 initial SPAR-H 1
CPS Review Comments Of NRC's SOP In-Process SPAR Model Results estimate appropriately reflects the failure likelihood within one hour, it is used in the following illustration (i.e., assuming use of independent recovery teams if previous recovery teams have been unsuccessful) to demonstrate that DG1 B wou ld be restored with a very high probability well before the 11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> time frame before batteries depleted.
Timeline Recovery Assumed DG Cumulative DG Interval Recovery Failure Recovery Failure Probabiility Probability T =0 to 1 hr Team 1 0.2 0.2 T =1 to 2 hr Team 2 0.2 0.04 T =2 to 3 hr Team 3 0.2 0.008 T =3 to 4 hr Team4 0.2 0.0016 o In this illustration, the likelihood of failure to recover the DG at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is less than 0.2%, two orders of magnitude less than the first recovery attempt by Team 1, with still more than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of margin to the time of battery depletion.
- In the SPAR-H model, the following adjustments could be made to better reflect the time available for recovery and related considerations:
o Selection of the "expansive time (>2x nominal and >30 min)" entry, instead of the "barely adequate" entry (for cognitive). Based on a recovery window of 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, and a recovery attempt time of less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (to complete the checklist), a ">1Ox time available" would be appropriate, but is not included in the SPAR-H model as an option.
The selection of an entry indicatiive of more time could reduce the HEP by up to two orders of magnitude.
o Although the SBO condition is an unusual (not expected) event, the presence of additional personnel, experienced in diesel generator maintenance, troubleshooting, and operation, and additional Operations staff, when coupled with the fact that many hours were available (due to low decay heat load) to initiate and complete restoration and mitigative actions, provides a basis for reducing the Stress selection from "High" to "Nominal" for this HEP with occurs early in the event timeline.
o Credit could be taken for self-correction of a diagnosis error and/or correction by other members of the crew (as illustrated in the table above with separate teams) to minimize undue conservatisms by reducing the impact of performance shaping factors (PSFs), as discussed in the SPAR-H Step-by-Step Guidance (INL/EXT-10-18533 Rev. 2).
2
CPS Review Comments Of NRC's SOP In-Process SPAR Model Results RPV Depressurization The dominant sequences in the NRC in-process model are sequences involving a failure to depressurize the RPV. Currently the NRC model is only crediting FLEX in the RPV depressurization node. CPS has noted that two other alternative methods (independent of FLEX) exist to support RPV depressurization (i.e., portable power packs and B.5.b equipment). The NRC has not yet included these other two methods in the modeling, noting that the in-process results are currently driven by HEPs. While that may be the case, CPS presents the following to illustrate that inclusion of the other two methods may still have a significant impact upon the results.
- The NRC HEP for FLEX electrical (supporting RPV depressurization via SRVs) was estimated to be 0.3. Although CPS does not agree with this 0.3 initial estimate, it is assumed (as a surrogate) to also apply independently to the two other depressurization strategies of portable power packs and B.5.b equipment. Multiplying these three HEPs together (0.3 x 0.3 x 0.3) yields a probability of 0.03 (i.e., an order of magnitude reduction associated with modeling only the FLEX electrical strategy.
o Different cues, locations, personnel, and timing of actions could reduce the dependencies between these actions. Even if moderate to high dependence is assumed, the joint HEP would reflect a reduction of 50%
or more as compared to the HEP of a single action.
- In the SPAR calculation, the FLEX electrical HEP could be reduced from 0.3 to 0.03 to model, in a surrogate fashion , inclusion of these two other alternate methods in addition to FLEX.
- The SPAR-H worksheets include PSFs for Experience and Ergonomics, among other things. For these PSFs, the following modifications could be applied:
o For Experience, the NRC applied a selection of "low" for many HEPs.
A selection of "nominal" is more appropriate. From the Step-by-Step Guidance document, "Nominal-more than 6 months experience and/or training. This level of experience/training provides an adequate amount of formal schooling and instruction to ensure that individuals are proficient in day-to-day operations and have been exposed to abnormal conditions."
- FLEX has been in place more than 6 months. Operators have trained on it. Simulations have been performed in which FLEX has been incorporated.
- Selection of "nominal" reduces impacted HEPs by approximately a factor of 3.
o For Ergonomics, the NRC applied a selection of "poor" for many HEPs.
A selection of "nominal" appears more appropriate. The Step-by-Step 3
CPS Review Comments Of NRC's SOP In-Process SPAR Model Results Guidance provides this input: "Ergonomics refers to the equipment, displays and controls, layout, quality, and quantity of information available from instrumentation, and the interaction of the operator/crew with the equipment to carry out tasks. " These considerations are design oriented rather than strictly environmental (e.g., lack of ventilation, portable lighting, radiation) which may be more appropriately accounted for as potential stressors. As noted in the SPAR-H Step-by-Step Guidance," ... the analyst should make an effort to avoid any "double counting" of specific influencing factors." If Stress is assessed as "High", this would generally encompass environmental considerations and Ergonomics would more appropriately be selected as "nominal".
High Pressure Injection The dominant sequences in the NRC in-process model are sequences involving a failure to depressurize the RPV. Without successful depressurization, the primary potential high pressure injection sources are RCIC and HPCS.
- RCIC was functional for the duration of the concurrent outage, but due to the high RPV water level the main stream lines were flooded. Use of RCIC with the RPV at high pressure would require waiting until the RPV boiled off inventory to a water level below the main steam lines. The NRC credited this with a HEP estimate of 0.75 (SPAR-H was not used to our knowledge). This value is judged high, and it is suggested that a more detailed HEP be developed. Based on other HEPs developed for the NRC risk assessment, a bounding value of 0.3 might be expected. This would represent a reduction factor of approximately 50% compared to the existing results for these dominant sequences.
- HPCS was in maintenance for a significant portion of the DG1 B unavailability.
The NRC modeled this configuration by assuming a HPCS T&M value of 0.9.
For the last 38.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> (~1.6 days) of that unavailability, CPS estimates that HPCS was restorable (e.g., fill and vent) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or less. This 1.6 days represents approximately 44% of the 3.6 day exposure period. If a screening HEP of 0.1 was applied to this time period when HPCS was restorable, a surrogate T&M estimate for HPCS could be applied in the model as follows:
o (0.1 HEP)* (0.44 restorable period)+ (1 .0 HEP)* (0.56 non-restorable period) = 0.60 LOOP Frequency The risk assessment result is contingent upon a LOOP event. A LOOP frequency of approximately 0.17/yr applicable to shutdown conditions was used in the NRC in-4
CPS Review Comments Of NRC's SOP In-Process SPAR Model Results process assessment based on available generic data. For the Exelon Risk Assessment, this generic data were reviewed and events that were found to only result from switchyard maintenance events or in a partial-LOOP were excluded, resulting in a LOOP frequency of 0.12/yr (a 29% frequency reduction), as documented in the risk assessment. CPS was not performing work in either switchyard during the exposure period in accordance with administrative protections. In discussions, the NRC noted that they disagreed with screening out the switchyard related events from the generic data. CPS notes that the administrative protections are put in place to reduce risk. Not accounting for the benefits of those protections implicitly includes a conservatism into the risk results (of approximately 29% per the Exelon estimate). If retained , this conservatism can be viewed to serve as a means to offset potential non-conservatisms that might be envisioned associated with the modeling of the event.
Summary Conclusions Exelon appreciates the opportunity afforded to it to meet, review, and discuss the in-process NRC risk assessment. While PRA practices seek to obtain a "best estimate" risk result, it is understood that at times conservative inputs are used to facilitate modeling simplicity. However, conservatisms should be evaluated for their potential impact upon the conclusions of the risk assessment.
Based on the comments above, the NRC in-process risk assessment is estimated to be well over an order of magnitude high based on current conservatisms, summarized as follows:
- The DG1 B Recovery HEP is estimated to be well over an order of magnitude high given the plants need to restore the DG and the available time.
- Not crediting two alternate RPV depressurization methods leads the dominant sequences to be approximately an order of magnitude high.
- Estimates of the SPAR-H inputs for calculating HEPs produces conservative HEPs that may be an order of magnitude high.
- Providing very limited credit for the use of RCIC and HPCS leads the dominant sequences to be high by approximately a factor two.
- The LOOP initiating event frequency includes events that may not be appropriate for the conditions examined, resulting in a frequency that could over-estimated by as much as 29%.
Inclusion of undue conservatism has the potential for producing results that stray from the objective of reflecting realistic inputs and plant response, thus impacting the conclusions of the risk assessment, which are discretized at orders of magnitude.
5
Note to requester: The attachm ent to this email has been withheld in its entirety under FO IA Ex. B5 (deliberative process privilege).
From : Kozak Laura To : Mitman Jeffrey Subject : FW: SOP recovery examples Date: Tuesday, September 18, 2018 12:49 :00 PM Attachments : Credit for recQ'.llLry exam~
FYI - I have been trying to provide other similar examples of how we treated recovery in SOP. Please see attached.
From: Kozak, Lau ra Sent: Tuesday, September 18, 2018 12:49 PM To: Lou den, Patrick <Patrick. Louden@nrc.gov>; Stoedter, Karla <Ka rl a.Stoedter@ nrc.gov>
Cc: Lara, Ju lio <Ju lio.Lara@nrc.gov>
Subject:
SDP recovery examp les (b)(5)
I will continue to find other ways to put the recovery credit in context.
(b )(5)
(b )(5)
From: Kozak Laura To : Mitman Jeffrey Subject : HEP for offsite power recovery Date: Tuesday, September 18, 2018 7:10: 00 AM Jeff
~
I evaluated the HEP using SPAR-Hand put it on the share point site. L_J Laura
Note to requester: The attachment to this email has been withheld in its entirety From: Kozak Laura under FO IA Ex. B5 To : Louden Patrick ( deliberative process Subject : one page summary on current Clinton status privilege).
Date: Tuesday, September 18, 2018 3:06 :00 PM Attachments: Briefin g ~
(b )(5)
From: Gjessner John To : Kozak Laura Subject : RE : Clinton Date: Tuesday, September 18, 2018 6:41:56 PM Great summary! !(b)(5)
From: Kozak, Lau ra Sent: Tuesday, September 18, 2018 3 :09 PM To: Giess ner, Jo hn <John.Giess ner@nrc.gov>
Subject:
Clinton Just FYI because I know you are interested.
One page briefing sheet for meeting with West on Thursday.
Laura
From: Kozak Laura To: Lara Julio Subject : RE: Clinton event tree Date: Tuesday, September 18, 2018 7:09:00 AM OK, don't get too hung up on the values in the tree, I likely modified those in the act ual model.
From: Lara, Jul io Sent: Tuesday, September 18, 2018 7:01 AM To: Koza k, Laura <Laura.Kozak@ nrc.gov>
Subject:
RE: Clinton event tree Friday discussison. Thx
o~-----
o~-----o~--
o o~-
From: Kozak, Laura Sent: Tuesday, September 18, 2018 6:58 AM To: Lara, Julio <Julio Lara@nrc gov>
Subject:
RE: Clinton event tree I wouldn't think so.
From: La ra, Julio Se nt: Tuesday, September 18, 2018 6:54 AM To: Kozak, Laura <Laura.Kozak@ nrc.gov>
Subject:
RE: Clinton event tree From: Kozak, Laura Se nt: Tuesday, September 18, 2018 6:54 AM To: Lara, Julio <Julio Lara@nrc gov>
Subject:
RE: Clinton event tree Battery depletion Core damage From: Lara, Julio Se nt: Tuesday, September 18, 2018 6:53 AM To: Kozak, Laura <Laura Kozak@nrc gov>
Subject:
RE : Clinton event tree From: Kozak, Laura Se nt: Monday, September 17, 2018 5:21 PM To: Lara, Julio <Juljo.Lara@nrc.gov>
Subject:
Clinton event tree This is my simple event tree
From: Lara Julio To: Kozak Laura
Subject:
RE: draft Clinton briefing Date: Tuesday, September 18, 2018 11 :16:15 AM For your consideration ..
I asked karla to get Mcgowan or tesar to help on the SDP comm tool as it could also help them .. within the comm tool, we should add some of these messages.
The red are my adds, if appropriate, to provide additional context o the uninformed.
The yellow is a but murky Clinton Division 2 EOG Significance Determination (9/20/18)
Key Messages Evaluation of the significance of the finding is in progress. The preliminary significance evaluation indicates the finding could be White.
The preliminary significance evaluation and assumptions have been discussed in detail with licensee staff.
(b )(5)
SUI-'
(b)(5)
Licensee Perspective Straightforward proceduralized response to recover the division 2 diesel generator.
Length of time available to provide mitigation response is substantial.
Multiple means exist for mitigation response.
Short exposure period Closed diesel generator air start receiver valves would be discovered within 15 minutes.
Operator failure probability is 4.6E-3 (successful 99.5% of the time). The failure probability is driven by execution errors.
Finding is of very low safety significance (E-8).
From: Kozak, Lau ra Sent: Tuesday, September 18, 2018 10:59 AM To: La ra, Jul io <J ul io.Lara@nrc.gov>
Subject:
draft Clint o n briefing Just FYI
Note to requester: The attachment to this email has been withheld in its entirety under FO IA Ex. B5
( deliberative process privilege).
From: Kozak Laura To : Louden Patrick: Stoedter Karla Cc : Lara Julio Subject : SDP recovery examples Date: Tuesday, September 18, 2018 12:48:00 PM Attachments: Credit for recovery examples.docx (b )(5)
I will continue to find other ways to put the recovery credit in context.
(b )(5)
(b )(5)
Note to requester: The attachment to this email has been withheld in its entirety under FO IA Ex. B5 From: Kozak Laura (deliberative process To : stoedter Karla privilege).
Subject : updated briefing Date: Tuesday, September 18, 2018 9:35 :00 AM Attachments: Briefing~
(b )(5)
From: Mitman Jeffrey To : Kozak Laura Subject : Clinton lnop Both EDGs SD SERP 09-20-18 (1).pptx Date: Wednesday, September 19, 2018 8:09 :31 AM Attachments: Cli!llil!l.lnop Both EDGs SD SERP 09-20-18 (1).oJID.
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=:r 4
Planned risk level (not to scale)
Version Dat e: 07-23-2018 Pre-Decisional 19
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From : Mitman Jeffrey To : Kozak Laura : ~ ; Felts Russell : Franovich Mike Subject : Clinton both EDGs Unavailable during Shutdown SERP Presentation Date: Wednesday, September 19, 2018 9:26 :47 PM Attachments: Cli!llil!l.lnop Both EDGs SD SERP 09-20-18 (2).PJID.
These are th e slides we intend to use during Thursday's SERP. They may be modified slightly based on review comments .
Because on the li mited time available , we only intend to cover Slides 3 through 7 du ri ng the meeting. These slides discuss:
- Conservatisms
- Non-conservatisms
- Risk results
- Sensitivity case results
- Dom inant sequences The rest are intended as supplemental/background information.
Jeff Mitman
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(b)(5)
Pre-Decisiona I 11 ~ U.S.NRC l,,1n,*rd ~.,,,._, Nu("fn ~ llfs:0l 11,,,7 C""""lP'ft" ProttttiNf Pt.op.Jr 1111d 1/N Envfronmo,t
(b)(5)
Pre-Decisiona I 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)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona 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
(b)(5)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona I 16 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)
Pre-Decisiona I 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)
Pre-Decisiona I 18 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
(b)(5)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona I 20 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)
Pre-Decisiona I 21 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)
Pre-Decisiona I 22 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)
Pre-Decisiona I 23 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 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 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 Pre-Decisional 24
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 Pre-Decisiona I 25 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
MANUAL REAC1OR lOW FRESSURE COOLANT ALlERNATE INJECTION INJ(CTION (no rlEXe<.Ott - CDS SWS FWS a nd HI PRESSURE INJECTIONS (HCS.CRD)
HEAi REMOVAL USING SUPPRESSON POOL Al TERNAtE HEAT REMOVAL {Always fails
,~ TAfllMENf VENTING- SO l Electri'cal Connection'Oiv.
3 to Div. 2
'-"=P-owe
- , -=R&-co
_ v_e_ry_
Correction Facbr for
_,.J--:*:---,, End Sate (Phase - CO)
-~!~!~-~ ays F~~~!"~
.q)I..NJIMY-rT> so-soc &>-l PI " """' I SO-All INJ I SD HPI I SO SPC-DCT - I&> All HEAT I 50-C\/S I ELEC.)CTIE c:-1 I I OK I
, - -( r-----( 1------o
,--.)-- o----[ =--()---==--
r
-o--
(:-1 I c:-
c:-1 I c:-I" I I I I I 7
8 9
10 OK OK OK OK I
I I
I I v--
CJ-------i__o--------f;;.w o---1" I CO-SO I
Lowpr~sure OK
- - -()-- - *U-- r c:-1
( : -_ I 13 OK OK I Cr [ " I
~ 0---- -v-- c:-1 I 15 OK I
- -*~- o - I- - - - - I j _ _ ~*w o--1" I o-i "'
w,, I H***L
- -* 0-- I CO-SO I o------G,.w o-- " 1 18 I_
I mJecoon *\._)"-- *0 - - U--- C:-1 c:-1 20 I OK OK II
~
o---- - -o-~ - -c I 21 I OK o----[ - *0--
CJ-------i__o--------f;;.w c:-1 o--1 22 I OK I I c:- I ,." II "'
co.so I*
o-------< I o- ~ I
~ :5 1ec1m::.:....__ __~ 0-1 25 I OK I L--- ~ -
.,- {_}-
~ ~ c : -1 TTCU-10H 26 I 0 26 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
(b)(5)
Pre-Decisiona I 28 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)
Pre-Decisiona I NRC 5nl11.,,7 C""" "u*11~ n Protttti"t Pt.op.fr and 1/N Envfron,n.o1t
From: Kozak Laura To : Mitman Jeffrey Subject : Clinton presentation Date: Wednesday, September 19, 201811 :18:00 AM Attachments: Cli!llil!l.lnop Both EDGs SD SERP 09-20-18 LCK rev.potx
- Jeff, I modified as requested and made a few other changes as well, please review.
Laura
~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)
(b)(5)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona I 3 ~ U.S.NRC l,,1n,*rd ~.,,,._, Nu("fn ~ llfs:0l 11,,,7 C""""lP'ft" ProttttiNf Pt.op.Jr 1111d 1/N Envfronmo,t
(b)(5)
Pre-Decisiona I 4 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)
Pre-Decisiona I 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)
Pre-Decisiona I 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)
Pre-Decisiona I 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
00 ro C
0
'in
- u QJ 0
I QJ I,,_
a..
I en ro C
0
'in
- u QJ 0
I QJ I,,_
a..
_J
(b)(5)
Pre-Decisiona I 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)
Pre-Decisiona I 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)
Pre-Decisiona I 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)
I Pre-Decisiona I 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
(b)(5)
Pre-Decisiona 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
(b)(5)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona I 16 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)
Pre-Decisiona I 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)
Pre-Decisiona I 18 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
(b)(5)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona I 20 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 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 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 Pre Decisional 21
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 Pre-Decisior ,a I 22 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
- 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
Pre Decisional 23 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
(b)(5)
Pre-Decisiona I 25 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)
L__ _ _ _ _ _ _ _ __ Pre-Decisional I } NRC 5nl11.,,7 C""" "u*11~ n Protttti"t Pt.op.fr and 1/N Envfron,n.o1t
(b)(5)
Pre-Decisiona I 27 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: Mitman Jeffrey To : Kozak Laura Subject : Clinton Update Date: Wednesday, September 19, 2018 9:32 :49 PM I've put the "final " model on SharePoint. I've updated the risk resu lts Excel Spreadsheet as well as the punch list. I sent the presentation to you and my management under separate email. Comments are always welcome.
Jeff Mitman
Note to requester: The first attachment to this email has been redacted in its entirety under FO IA Ex. B5 (deliberative process privilege), the second attachment is non-responsive due to narrowing the request to exclude licensee originated documents.
From: Stoedter Karla To : Dickson Billy Subject : FW : clinton risk comm tools Date: Wednesday, September 19, 201811 :16:00 AM Attachments: FW On~RllgJlLll.lmma_f\/.J)f Qreillilinary Whi~ o n Division 3 SX pump failure.msg FW l nfor1J1ation Oolv QaJlis Bes.se_sue.is.su.e.ms.Q From: Lara, Julio Sent: Tuesday, September 18, 2018 8 :33 AM To: Stoedter, Karla <Karla .Stoedter@nrc .gov>
Subject:
clinto n risk comm tools Let's talk sometime today. Thx
(b)(5)
(b)(5)
From: Kozak Laura To: Lara Julio Subject : RE:
Date: Wednesday, September 19, 2018 7 :52:00 AM Attachments: image002.ong Perfectly clear From: Lara, Julio Sent: Wednesday, September 19, 2018 7:07 AM To: Koza k, Laura <Laura.Kozak@ nrc.gov>
Subject:
(b )(5)
Julio Lara, P.E.
Deputy Director Division of Reactor Projects, RIii 630-829-9601
~ Fom,i"* ,,. Saf*IJ*
Empowering Otl,er)
Strfring for £.'l;C't'llt'IIU
From: Mitman Jeffrey To : Robert E Buell Cc: sancaktar senm: Kozak Laura Subject : RE: Clinton Date: Wednesday, September 19, 2018 2:34:25 PM Importance: High Bob, this solve the problem!
Thanks for the help.
Jeff Mitman From: Robert F. Buell [ma ilt o:robert. buell @inl.gov]
Se nt: Wednesday, September 19, 2018 3:21 PM To: M itma n, Jeffrey <Jeffrey.M itma n@nrc.gov>
Subject:
[External_Sender] Clint on Jeff, Try t hese rules:
I M itma n's Shutdown Rules (b )(5)
Robert Buell (b)(6) ......
L= ***** *- _ _ __,
From : Kozak Laura To : Sanchez santjago Elba Subject : Another req uest - not urgent Date: Thursday, September 20 , 2018 4:09 :00 PM Attachments: imageQQJ_,_ong Elba See loads below off 480V bus 1B - most of which are not on during FLEX. Can you find out for me the specific loads on DG Building MCC 1B, 1AP61 E? l(b)(5) I Thanks Laura (b)(5)
From: Kozak Laura To : stoedter Karla: Sanchez Santiago Elba Subject : briefing Date: Thursday, September 20 , 2018 9 :00:38 AM Attachments: Briefing~
Note to requester: The attachment to this email has been withheld in its entirety under FO IA Ex. B5 (deliberative process privilege).
(b )(5)
From : Kozak Laura To : west Steven : Louden Patrick : Lara Julio ; Riemer Kenneth : Cameron Jarnnes : Stoed ter Karla; ~
Santiago Elba Subject : Clinton - what recovery HEP value would result in a Green finding Date: Thursday, September 20, 2018 1 :04:00 PM To answer Steve's Q Laura
Note to requester: The second attachment to this From: Kozak Laura email has been withheld in To : Tesar Daniel its entirety under FOIA Ex.
Subject : Clinton B5 ( deliberative process Date: Thursday, September 20, 2018 10:51:00 AM privilege).
Attachments: Qinton Event Trees.Qdf Brielin.a.docx
Clinton Event Trees Loss of Ollsite Power - EMERGENCY POWER AC POWER RECOVERY # End State M4LATE SUPPLY- (DIV I AND II) - 24 / 1 Hours (Phase - CD)
SD-M4L-LOOP SD-EPS SD-AC-REC-24H 1 SD-M4L-LOOP-T 0 0 0 I 0 I
2 I
SD-M4L-LOOP-T >
0 I 0 I
I 3
I I
SD-M4L-LOOP-T >
Elecifi'cal-Cori'riectio'nDiV.
3toDiv. 2
<DUMMY-FT> IINJEc 11u,w,, ISD*S~~IE~ng Fl FX I
~u-~ ,
dunng El Al
' I . - - - '-"
ELEC_XTIE c-1 ITTCU . !U!!n~c*~ve:!1L-_ ---";:=2=:====::::===;
C -~ I--------;:O~K I II
)FX . SD-HPI *"--*" ~ -- - '-' *"-~ 1 I I OK
.(.,__ c-141 o-1, II o-[o----[ ~-0-- , _
I c-1 5 I
-~ I ~CD-SD-I c---j_o--------J;;"' o-1: " I
- "-- c-1 V
o-1 II " II 8 c-1 I o-[o----[ r'I---- ,
,(.,______ c-l 9
~.." o-1" I CD-SD" II 10 I
__ 1
~ ~ I113" II *
'-- o-Lo-----{;;~
' - - -r---r'- '-" - OK I
, tion@lowtemp
""""**n,.
~o----[ v -~
c
~
-1 : ::I "
i I
Noinj~tion c-1171 .
- ~
18 .
=::=;c~D-sDi---l .
- "---- ~ I I 1 19 1
OK I c-l 20 I o----[o-L ~
1 lnjection@hlgh ~re o-----{;; c-l C- 21 I II 22 I Highpr~SLl'8 c -l al 1 1 CD-SD
- I I 24 I .
- "---- ~ I I 25 OK I
__ ~_ c-----ber:---co-1" I TTCU-1DH I
(b )(5)
From : Kozak Laura To : Tesar Daniel Subject : Clinton Date: Thursday, September 20 , 2018 10 :53 :31 AM Attachments: Cli!llil!l.lnop Both EDGs SD SERP 09-20-18 (2) .PJID.
~ U.S.NRC United $races Nu cl c-.i r Rcgularory Co mmi ssion Protecting People and the Environment (b)(5)
(b)(5)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona I 3 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)
Pre-Decisiona I 4 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)
Pre-Decisiona I 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)
Pre-Decisiona I 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)
Pre-Decisiona I 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)
Pre-Decisiona I 8 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
en ro C
0
'in
- u QJ 0
I QJ I,,_
a..
(b)(5) f U.S.NRC Pre-Decisiona I 10 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)
Pre-Decisiona I 11 ~ U.S.NRC l,,1n,*rd ~.,,,._, Nu("fn ~ llfs:0l 11,,,7 C""""lP'ft" ProttttiNf Pt.op.Jr 1111d 1/N Envfronmo,t
(b)(5)
Pre-Decisiona I 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)
Pre-Decisiona I 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
(b)(5)
Pre-Decisiona 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
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Pre-Decisiona I 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
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Pre-Decisiona I 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
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Pre-Decisiona I 18 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
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Pre-Decisiona I 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
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Pre-Decisiona I 20 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
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Pre-Decisiona I 21 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
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Pre-Decisiona I 22 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
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Pre-Decisiona I 23 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
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From: Mitman Jeffrey To : Kozak Laura Subject : Clinton Answers Date: Thursday, September 20 , 2018 12:59 :57 PM Laura,. - e , - , . . , . , , , , - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - .
(b)(5)
Jeff Mitman
From : Kozak Laura To : Tesar Daniel Subject : Clinton documents Date: Thursday, September 20, 2018 10:45:21 AM Attachments: Clinton EOG Unavailability $ERP rev2.docm
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)(S) Exh1-1 0609.0STP
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Issue Date: LJ Exh1 -2 0609.0STP
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Issue Date: Exh1-10 0609.0STP
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Issue Date: l(b)(5) I Exh1-16 0609.0STP
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Issue Date: LJ Exh1-19 0609.0STP
Issue Date: ~ Att1-1 0609.05TP From : Stoedter Karla To : Cameron Jamnes: Riemer Kenneth : West Steven Subject : Clinton EDG information Date: Thursday, September 20, 2018 10:28:00 AM Attachments: CLl201805~.
ClintoJLS.ERP o.ackaae..msq The IFRB/SERP worksheets and the SIT report (which contains the documented PD and apparent violation) are attached for your convenience. Let us know if you have further questions.
Karla
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 2443 WARRENVILLE ROAD, SUITE 210 LISLE, ILLINOIS 60532-4352 August23, 2018 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- NRG SPECIAL INSPECTION REPORT 05000461/2018050
Dear Mr. Hanson:
On June 29, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a reactive inspection at your Clinton Power Station. On August 3, 2018, the NRC inspectors discussed the results of this inspection with Mr. T . Stoner and other members of your staff. The results of this inspection are documented in the enclosed report.
Based on the results of this inspection, the NRC identified two issues that were evaluated under the risk significance determination process. Both of these issues were determined as having very-low safety significance (Green). The NRC has also determined that two violations are associated with these issues. Because the licensee initiated condition reports to address these issues, these violations are being treated as Non-Cited Violations (NCVs), consistent with Section 2.3.2 of the Enforcement Policy. These NCVs are described in the subject inspection report.
Additionally, Results Section (4) of the enclosed report discusses a find ing with an associated apparent violation for which the NRC has not reached a preliminary significance determination.
This finding involved the apparent failure of licensee personnel to follow multiple procedures resulting in the unavailability of the Division 2 Emergency Diesel Generator when it was relied upon for plant safety. Since the NRC has not made a final determination in this matter, a Notice of Violation is not being issued for this inspection finding at this time. In addition, please be advised that the characterization of the apparent violation described in the enclosed inspection report may change as a result of further NRC review.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington , DC 20555-0001; with copies to the Regional Administrator, Region Ill; the Director, Office of Enforcement; and the NRC Resident Inspector at the Clinton Power Station.
B. Hanson If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 ; with copies to the Regional Administrator, Region Ill ; and the NRC resident inspector at Clinton Power Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/readinq-rm/adams .html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding. "
Sincerely, IRA/
Karla Stoedter, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62 Enclosure :
Inspection Report 05000461 /2018050 cc: Distribution via LISTSERV
B. Hanson Letter to Bryan Hanson from Karla Stoedter dated August 23, 2018
SUBJECT:
CLINTON POWER STATION- NRG SPECIAL INSPECTION REPORT 05000461/2018050 DISTRIBUTION:
Jeremy Bowen RidsNrrDorlLpl3 RidsNrrPMClinton Resource RidsNrrDirslrib Resource Steven West Darrell Roberts Richard Skokowski Allan Barker DRSIII DRPIII ROPassessment.Resource@nrc.gov ADAMS Accession Number: ML18235A170 OFFICE RIii I RIii I RIii I I NAME CPhillips:bw RSkokowski KStoedter DATE 8/15/2018 8/15/2018 8/23/2018 OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION REGION Ill Docket Numbers: 50-461 License Numbers: NPF-62 Report Numbers: 05000461/2018050 Enterprise Identifier: 1-2018- 050-0002 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station Location: Clinton, IL Dates: June 25 through June 29, 2018 Inspectors: C. Phillips, Project Engineer R. Murray, Senior Resident Inspector, Quad Cities J. Draper, Health Physicist Approved by: K. Stoedter, Chief Branch 1 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) monitored the licensee's performance by conducting a Special Inspection at Clinton Nuclear Power Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operatinq/oversiqht.html for more information. Findings and violations being considered in the NRC's assessment are summarized in the table below.
List of Findings and Violations Failure to Follow Multiple Procedures Cornerstone Significance Cross-Cutting Report Section Aspect Mitigating TBD [H .2] - Human 93812- Special Systems AV 05000461/2018050-01 Performance, Inspection Open Field Presence EA- 18-104 On May 17, 2018, a To-Be-Determined (TBD) finding and an associated Apparent Violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and Technical Specification 3.8.2, Condition B.3, were self-revealed for the licensee's failure to follow multiple procedures that affected quality.
This resulted in the unavailability and inoperability of the Division 2 Emergency Diesel Generator when it was relied upon for plant safety.
Failure to Identify a Condition Adverse to Quality Cornerstone Significance Cross-Cutting Report Section Aspect Mitigating Systems Green [H. 12]- Human 93812- Special NCV 05000461 /2018050-02 Performance, Inspection Open/Closed Avoid Comolacencv On May 17, 2018, a Green finding and an associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," were self- revealed for the licensee's failure to promptly identify that the safety-related Division 2 Emergency Diesel Generator had its starting air receivers isolated, which was a condition adverse to quality that rendered the emerqency diesel qenerator inoperable and unavailable.
2
Equipment Operator Rounds Points Inadequate Acceptance Criteria Cornerstone Sign ifica nee Cross-Cutting Report Section Aspect Mitigating Systems Green [H .6] - Human 93812-Special NCV 05000461/2018050- 03 Performance, Inspection Open/Closed Design Margins On May 17, 2018, a Green finding and an associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," were self-revealed for the licensee's failure to include appropriate quantitative acceptance criteria for the Division 2 Emergency Diesel Generator parameters to ensure the Division 2 Emergency Diesel Generator could perform its safety function.
Additional Tracking Items None.
3
INSPECTION SCOPE Inspections were conducted using the appropriate portions of the inspection procedure (IP) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light-Water Reactor Inspection Program - Operations Phase." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess !l icensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES-TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 93812- Special Inspection In accordance with the Special Inspection Team Charter (ADAMS Accession Number ML18158A170), the inspection team conducted a detailed review of the event that led to both Division 1 and Division 2 Emergency Diesel Generators (EDGs) being inoperable and unavailable. The inspectors reviewed the following areas.
(1) Develop a complete sequence of events related to the inoperability and unavailability of the Division 1 and Division 2 alternating current (AC) power systems from May 9 through May 17, 2018. The chronology should include plant mode changes, changes in the electrical power, decay heat removal , and inventory control shutdown safety/risk areas.
(2) Understand the increased shutdown risk condition which existed when no emergency AC power sources were available for a period of approximately 3.5 days. Review the planned shutdown safety configuration compared to the actual configuration that existed.
Understand the licensee's ability to respond to and mitigate a loss of offsite power event given the unavailability of both onsite emergency AC power sources.
(3) Review the licensee's cause analysis efforts and determine if the evaluation's level of detail is commensurate with the significance of the problem.
(4) Determine the probable cause(s) for the unavailability of the Division 1 and Division 2 EDGs during the 2018 refueling outage.
(5) Understand whether there were any deficiencies in operator training (both licensed and non-licensed operators) which contributed to the EDG unavailability and the failure to identify the condition across multiple operating shiifts.
(6) Evaluation of the licensee's compliance w ith, and adequacy of, procedural guidance for performing system alignments, controlling equipment configuration, performing equipment tag-outs and control room log keeping as it pertains to the cause(s) of the event.
The inspectors identified several examples of situations where procedures and work instructions that were in place at the time of the event were not followed. These 4
examples are discussed in detail in an observation box in the results section associated with paragraph (4) of this report.
(7) Evaluate licensee planned and completed correctiive 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.
(8) Determine whether recent internal and external operating experience involving configuration control, risk management and oversight of activities were appropriately evaluated and determine the adequacy of any corrective actions planned or completed.
INSPECTION RESULTS 93812-Special Inspection (1) Develop a complete sequence of events related to the inoperability and unavailability of the Division 1 and Division 2 AC power systems from May 9 through May 17, 2018. The chronology should include plant mode changes, changes in the electrical power, decay heat removal, and inventory control shutdown safety/risk areas.
Observation I IP 93812 On May 9, 2018, Clinton Power Station (CPS), Unit 1, was in Mode 5 during Refueling Outage C1R18. The reactor cavity was filled, and at 9:36 p.m. the Division 2 4160 Volt alternating current (Vac) bus (1 B1) was energized from the reserve auxiliary transformer (RAT) to end a scheduled bus 1B1 maintenance window. The Division 1 AC distribution system, Division 1 EOG, and residual heat removal (RHR) 'A' system were operable during the 1B1 bus outage and remained operable upon restoration of bus 1B 1.
Earlier on May 9, 2018, the Division 2 EDG had been inoperable and unavailable as a result of the 1B1 bus outage. At 5:25 p.m., Clearance Order (C/O) 139455 was removed from the Division 2 EOG as part of 1 B1 restoration activities. This C/O included a Special Instruction that stated "Restore Div 2 DG [diesel generator] to standby per CPS 3506.01 P002 [Division 2 Diesel Generator Operations; Revision 3a] in conjunction with C/O removal." The inspectors found procedure CPS 3506.01 P002 was not performed 1in conjunction with the C/O closure.
Instead , a senior reactor operator (SRO 1) placed a note in the control room log stating CPS 3506.01P002 needed to be performed after restoration of the Division 2 shutdown service water (SX) system. Because CPS 3506.01 P002 was not completed as part of the C/O closure, the position of the Division 2 EOG air receiver isolation valves was being controlled by the control room log entry instead of through an approved licensee process. By not completing CPS 3506.01 P002 at that time, Division 2 EOG air receiver isolation valves (1DG160 and 1DG161) were left shut. Following the closure of the C/O, this log entry was the only method the licensee used to track the need to restore the Division 2 EOG to standby per CPS 3506.01P002.
On May 10, 2018, during the day shift, a senior reactor operator (SRO 2) directed a non-licensed operator to perform a portion of CPS 3506.01 P002 to restore fuses for the Division 2 EOG lubrication system, which had previously been removed from service prior to the 1B1 bus maintenance. When the non-licensed operator had completed the partial procedure, SRO 2 had already turned over duties to a different senior reactor operator (SRO 3), so the non-licensed operator returned the partial completed procedure to SRO 3.
5
Even though the complete CPS 3506.01 P002 procedure had not been performed, SRO 3 believed that all activities required to restore the Division 2 EDG had been completed.
On May 11 , 2018, at 2:30 a.m., SRO 3 declared the Division 2 EDG available after Division 2 SX was restored and made available. At this time, the Division 2 EDG starting air valves (1DG160 and 1DG161) remained closed, isolating starting air from the EDG air start motors, making the EDG unable to start on any demand signal. On May 11, 2018, at 5:10 a.m., the licensee installed the reactor cavity gate in preparation for cavity drain down and reactor head installation . The cavity draiin began at 9:43 a.m. and was completed at 1 :54 p.m. The licensee began tensioning the reactor head studs at 12:20 a.m. on May 12, 2018, and completed tensioning the studs at 1:51 a.m., at which time operations department personnel declared the Unit in Mode 4.
On May 12, 2018, at 8:00 a.m., the licensee completed OP- M - 108- 106, "Equipment Return to Service," Revision 5, for the Division 2 Nuclear System Protection System (NSPS),
Division 2 essential switchgear cooling (VX), Division 2 direct current (DC), and Division 2 EDG, and declared each of these systems operable. The licensee did not perform post-maintenance testing on the Division 2 EDG as no maintenance was performed on the EDG.
On May 13, 2018, operations secured the RHR 'A' pump from operation in shutdown cooling mode from 2:24 a.m. until 112:53 p.m. to facilitate the reactor pressure vessel pressure test.
During this time, the emergency reserve auxiliary transformer (ERAT) (which had been unavailable since May 5, 2018, at 5:03 p.m.), the second source of offsite power to the 4160 Vac safety-related buses, was declared available at 5:15 a.m. At 11 :09 p.m., RHR 'B' was declared operable for shutdown cooling mode, and at 11 :28 p.m., RHR 'A' was secured and RHR 'B' was started in shutdown cooling mode.
On May 14, 2108, at 12:30 a.m., since the licensee was unaware that the Division 2 EDG was inoperable and unavailable due to its inability to start caused by the 1DG 160 and 1DG 161 valves being closed, the licensee began a scheduled maintenance window for the Division 1 4160 Vac bus ( 1A 1). As a result of taking bus 1A 1 out of service, the Division 1 EDG was declared inoperable and unavailable along with other equipment powered from bus 1A1, including the low pressure core spray (LPCS) and RHR 'A' systems.
On May 16, 2018, at 1:30 a .m., the licensee completed filling and venting the high pressure core spray (HPCS) system following an extended maintenance window. On May 17, 2018, at 11 :18 a.m., operations decllared HPCS available, and after post-maintenance testing of the system on May 18, 2018, at 6:21 p.m., HPCS was declared operable.
On May 17, 2018, at 3:03 p.m., a non-licensed operator performing shift rounds identified that the 1DG160 and 1DG161 valves were closed and reported this condition to the control room.
The licensee declared the Division 2 EDG inoperable and unavailable and investigated the condition. The licensee restored the valves to the open position and declared the Division 2 EDG available at 3:45 p.m. After the licensee performed OP- AA- 108- 106, the licensee declared the Division 2 EDG operable at 9:04 o.m.
(2) Understand the increased shutdown risk condition which existed when no emergency AC power sources were available for a period of approximately 3.5 days. Review the planned shutdown safety configuration compared to the actual configuration that existed.
6
Understand the licensee's ability to respond to and mitigate a loss of offsite power event given the unavailability of both onsite emergency AC power sources.
Observation I IP 93812 As a result of several human performance errors the Division 2 EOG was inoperable and unavailable for over 6 days without the licensee's knowledge. Both Division 1 and Division 2 EDGs were inoperable and unavailable for over 3 days, May 14 through May 17, 2018, which was not allowed per Technical Specification (TS) 3.8.2 (this violation is in the results section of the report for Paragraph (4)).
Had a loss of offsite power event occurred between May 14 and May 17, 2018, there would have been an immediate station blackout (SBO) event. The inspectors determined that the Division 2 EOG was recoverable. The inspectors determined that there were no other plant conditions that deviated from the stations shutdown risk plan during the time that both EDGs were unavailable. The inspectors determined that the licensee could have responded to an SBO in one of at least three ways. The licensee could have declared an extended loss of AC power (ELAP) event and deployed FLEX equipment. Additionally, the smaller Division 3 EOG could have been started and cross-tied to the Division 2 4160 Vac bus. The inspectors determined that the Division 3 EOG would have supported enough loads to restore one train of shutdown cooling. Finally, two diesel driven fire pumps and the safety-relief valves were available to provide feed and bleed coolinq to the reactor core if necessary.
(3) Review the licensee's cause analysis efforts and determine if the evaluation's level of detail is commensurate with the significance of the problem.
Observation I IP 93812 The inspectors interviewed the licensee's root cause team lead and two additional root cause team members. At the time the inspection team arrived on site the licensee had completed their initial analysis of the events but had neither documented the results of their review nor had station management reviewed and approved the results. The inspectors reviewed numerous procedures, toured the applicable locations in the plant, and interviewed several operators involved in this event. The inspectors determined that the licensee appeared to be followinq their quidance for root cause investiqations.
(4) Determine the probable cause(s) for the unavailability of the Division 1 and Division 2 EDGs during the 2018 refueling outage.
Observation I IP 93812 The inspectors determined that the cause of the event was the licensee's failure to follow multiple procedures and work instructions. The restoration instructions associated wiith the clearing of C/O 139455 that resulted in this event were not followed. The instructions stated that the performance of CPS 3506.01 P002, "Division 2 Diesel Generator Operations," was required to be in conjunction with the clearance of the C/O. The standard Clinton operation's process for clearing out-of-service tags was to leave the valves in the out-of-service position and then complete a standby lineup afterwards to reposition the valves to the correct position.
The SRO (SRO 1) that cleared C/O 139455 did not perform the standby lineup (CPS 3506.01 P002) in conjunction with the clearing of the out-of-service because safety-related cooling water (SX) to the EOG was still inoperable. This resulted in the EOG air receiver isolation valves ( 1DG 160 and 1DG 161) remaining closed when the out-of-service cards were cleared. The inspectors asked the licensee if 1DG160 and 1DG161 needed to 7
remain closed to protect the EDG based solely on the status of the safety-related cooling water to the EDG at the time. The licensee responded that it was not required for 1DG160 and 1DG 161 to remain closed to protect the EDG based on the plant status at the time C/O 139455 was cleared. The failure to follow the C/O direction to complete procedure CPS 3506.01 P002 was a failure to follow work instructions.
The SRO (SRO 1) stated in the control room operating logs that CPS 3506.01 P002 was required to be performed at some later date. The inspectors identified that the specific abnormal positions of 1 DG 160 and 1DG 161 were not logged into the operations log, only the requirement to complete CPS 3506.01 P002. The inspectors also identified that no Exelon procedure existed that required or allowed the tracking of valves in an abnormal position by the use of the control room logs. A Clinton site specific procedure existed that allowed tracking of the status of some specific equipment in the operator logs until the end of the shift but that procedure was not applicable to this situation.
Valves 1DG 160 and 1DG 161 were normally locked open valves. Exelon procedure OP- AA- 108- 103, "Locked Equipment Program," Revision 2, Step 4.1.5, stated, "If plant conditions require a locked component to be positioned in a manner other than that indicated on the locked equipment checklist or approved procedure, then UNLOCK and REPOSITION equipment in accordance with OP- AA- 108- 101 , 'Control of Equipment and System Status."'
Procedure OP-AA-108- 101 , "Control of Equipment and System Status," Revision 14, Step 4.1.1.1, stated, "Utilize an ACPS [abnormal component positioning sheet] for aligning equipment outside of routine operations. For situations, excluding routine operation, where a component, system, or structure is required to be placed in a position differing from its normal lineup, the alignment must be done utilizing an Abnormal Component Position Sheet (ACPS).
The ACPS will document proper evaluation, performance and restoration of the alignment, ensuring plant configuration control is maintained." An ACPS was not used to track the positions of 1DG160 and 1DG161. This was a failure to follow procedure.
Exelon procedure OP-AA-108-106, "Equipment Return to Service," Revision 5, Step 4.3, required that "if equipment will not be restored to the Equipment Line-up/Restoration position or the original condition, then another approved equipment status control mechanism shall be used to document equipment status (i.e. Equipment Status Tag, administrative clearance/tagout). Procedure OP- AA- 108- 101, 'Control of Equipment and System Status,'
shall be used to document abnormal equipment configuration and shall be immediately applied following equipment restoration." This was not performed and constituted a failure to follow procedure.
In addition, Exelon procedure OP-AA-109-101, "Clearance and Tagging," Revision 12, Step 10.2.1 , stated, "If a lift position is determined to be different from the normal lineup position for the present plant condition and not tracked by another C/O or procedure, then Shift Management shall be notified and equipment tracking initiated." In an interview between the inspectors and SRO 1, he stated that he thought the positions of 1DG 160 and 1DG 161 were being tracked via a procedure (CPS 3506.01 P002). Licensee operations management stated that entering the procedure into the operations log was not the same as tracking via procedure. Tracking the position of the air start valves by the use of another C/O or procedure was not performed and constituted a failure to follow procedure.
When the licensee restored safety-related cooling water to the EDG, a second SRO (SRO 2) directed a partial performance of CPS 3506.01 P002 in order to restore fuses for control power for the EDG lube oil pumps. Per the inspectors interview with SRO 2 the fuses were pulled 8
during a previous outage activity to prevent starting of the DC lube oil pumps when the AC power was removed for the 1B1 bus outage.
When the non-licensed operator returned with the partially performed copy of CPS 3506.01 P002, he turned it over to a third SRO (SRO 3). Since procedure CPS 3506.01 P002 was not marked as a partially performed procedure, SRO 3 believed it to be a fully performed procedure.
Even though the complete CPS 3506.01 P002 procedure had not been performed, SRO 3 believed that all restoration activities on the Division 2 EOG had been performed. Therefore after Division 2 SX was restored and made available on May 11 , 2018, SRO 3 declared the Division 2 EOG available. At this time, the Division 2 EOG starting air valves (1DG160 and 1DG 161) remained closed, preventing starting air from reaching the EOG air start motors, making the EDG unable to start on any demand signal.
The next day on May 12, 2018, at 8:00 a.m., the licensee determined that OP-AA-108-106, "Equipment Return to Service," for the Division 2 NSPS, Division 2 essential switchgear cooling (VX), Division 2 direct current (DC) and Division 2 EDG, was complete and declared each of these systems operable. The licensee did not perform post-maintenance testing on the Division 2 EDG as no maintenance was performed on the EDG. The inspectors determined operating management personnel did not perform procedure OP- AA- 108- 106, "Equipment Return To Service," Revision 5, Step 4.4.9, which stated, "Applicable Operating procedures are complete and any equipment line-ups directed to be completed by the Operating Procedures are completed," because CPS 3506.01P002 had not been completed.
In addition, licensee operations department management personnel did not perform Step 4.4.14, which stated, "The system/equipment has been walked down as appropriate to verify that it can be safely operated to fulfill its design function." The SRO told the inspectors that because no maintenance was performed on the EDG he did not think it was necessary.
The failure to perform these steps was a failure to follow procedure .
Failure to Follow Multiple Procedures Cornerstone Sianificance Cross-Cuttina Aspect Report Section Mitigating TBD [H.2] - Human 93812-Special Systems 05000261/2018050- 01 P,erformance, Field Inspection Open Presence EA-18-104 On May 17, 2018, a To-Be-Determined (TBD) finding and an associated Apparent Violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and Technical Specification 3.8.2, Condition B.3, were self-revealed for the licensee's failure to follow multiple procedures that affected quality. This resulted in the unavailability and inoperability of the Division 2 Emergency Diesel Generator when it was relied upon for plant safety.
==
Description:==
Earlier on May 9, 2018, the Division 2 EDG was inoperable and unavailable as a result of the 1B1 bus outage. At 5:25 p.m., C/O 139455 was removed from the Division 2 EOG as part of bus 1B1 restoration activities. This C/O included a Special Instruction that stated "Restore Div 2 DG to standby per CPS 3506.01 P002 [Division 2 Diesel Generator Operations; Revision 3a)] in conjunction with C/O removal." This procedure (CPS 3506.01 P002) was not performed prior to closure of the C/O; and an SRO (SRO 1) noted in the control room 9
narrative logs that the Division 2 EOG remained in maintenance lockout pending restoration of the Division 2 shutdown SX system from its planned maintenance window, and that restoration per CPS 3506.01 P002 would need to be performed to restore the Division 2 EOG to standby. By not completing CPS 3506.01 P002, isolation valves from the EOG starting air receiver (1DG160 and 1DG161) were left shut. Following the closure of the C/O, this log entry was the only method the licensee used to track the need to restore the Division 2 EOG to standby per CPS 3506.01 P002.
On May 10, 2018, during the day shift, a senior reactor operator (SRO 2) directed a non-licensed operator to perform a portion of CPS 3506.01 P002 to restore fuses for the Division 2 EOG lubrication system, which had previously been removed from service prior to the 1B1 bus maintenance. When the non-licensed operator had completed the partial procedure, SRO 2 had already turned over duties to a different senior reactor operator (SRO 3), so the non-licensed operator returned the completed partial procedure to SRO 3.
Even though the complete CPS 3506.01 P002 procedure had not been performed, SRO 3 believed that all restoration activities had been performed. After Division 2 SX was restored and available on May 11 , 2018, at 2:30 a.m., SRO 3 declared the Division 2 EOG available.
At this time, the Division 2 EOG starting air valves (1DG160 and 1DG161) remained closed ,
isolating starting air from the EOG air start motors, making the EOG unable to start on any demand signal.
On May 14, 2018, at 12:30 a.m., since the licensee was unaware that the Division 2 EOG was inoperable and unavailable due to its inability to start caused by the 1DG 160 and 1DG 161 valves being closed, the licensee began a scheduled maintenance window for the Division 1 4160 Vac bus ( 1A 1). As a result of taking bus 1A 1 out of service, the Division 1 EOG was declared inoperable.
On May 17, 2018, at 3:03 p.m., a non-licensed operator performing shift rounds identified that the 1DG160 and 1DG 161 valves were closed and reported this condition to the control room .
The licensee declared the Division 2 EOG inoperable and investigated the condition.
Corrective Actions: Operations Director memos were sent to the operations shift managers related to accountability and procedure use and adherence. These memos, which were required to be acknowledged by all operations department personnel and briefed by the operations shift managers, covered various administrative procedural requirements including:
procedure use and adherence, control of plant equipment, stop work criteria, operations decision making, and operability procedure requirements. The inspectors reviewed an operations director memo from May 18, 2018, "Issue Response Expectation for Clinton Operations Management." The inspectors also reviewed an operations director memo from May 23, 2018, "Manager Accountability for Performance." Interviews with operations department personnel indicated personnel were aware of the content of the memos.
The Operations Director and operations department leaders conducted face-to-face discussions with each member of the operations department.
Just-in-time training was given to all operations department staff on the requirements of HU-AA-104-101 , "Procedure Use and Adherence," Revision 5. The inspectors' Interviews with operations personnel indicated that personnel were aware of the requirements of HU- AA- 104- 101 .
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The licensee changed the clearance and tagging method to include signed restoration steps. Restoration steps were previously included as restoration instruction "notes." These notes were expected to be completed as a procedure; however, the clearance order was allowed to be closed without documenting that these restoration steps had been completed. The inspectors reviewed several clearance orders and verified the licensee's corrective action was being implemented.
The licensee implemented a "Procedure-in-Progress" program for procedures that are not completed within one shift. The inspectors toured the control room and discussed the process with operators and observed it was being implemented.
The licensee conducted a three day stand-down with all station personnel and covered case studies and learnings from the event. The inspectors reviewed the material covered during the stand-down and interviewed plant personnel, who were aware of the details of the stand-down.
The licensee revised the equipment operator rounds points to include logging emergency diesel generator starting air manifold pressures, located down-stream of the air tank isolation valves. The inspectors reviewed the revised 'C' area rounds points and verified operators were logging EDG air manifold pressures.
Operations shift managers were reviewing logs and at least two completed procedures at the end-of-each shift. The inspectors requested to review any condition reports associated with these reviews and were informed that since this had been implemented, there had been no condition reports generated as a result of these shift manager reviews.
Corrective Action
Reference:
Action Request (AR) 4138790, "Division 2 DG Air Receiver Found Isolated Rounds," dated May 17, 2018.
Performance Assessment:
Performance Deficiency: The licensee failed to perform activities affecting quality in accordance with prescribed procedures and work instructions as required by 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings," that resulted in the unavailability of the Division 2 EDG when it was relied upon for plant safety. Specifically, the licensee failed to:
Perform CPS 3506.01 P002, "Division 2 Diesel Generator Operations," Revision 3a, in conjunction with the removal of C/O 139455 as required by the C/O restoration instructions on May 9, 2018.
Perform OP- AA- 108-103, "Locked Equipment Program," Revision 2, Step 4 .1 .5, which stated, "If plant conditions require a locked component to be positioned in a manner other than that indicated on the locked equipment checklist or approved procedure, then UNLOCK and REPOSITION equipment in accordance with OP- M - 108- 101, 'Control of Equipment and System Status."' Valves 1DG160 and 1DG161 were normally locked open valves.
Licensee procedure OP-AA-108-10 1, "Control of Equipment and System Status,"
Revision 14, Step 4 .1.1.1, stated, "Utilize an ACPS [abnormal component positioning sheet]
for aligning equipment outside of routine operations. For situations, excluding routine operation, where a component, system, or structure is required to be placed in a position differinq from its normal lineup, the alionment must be done utilizinq an Abnormal Component 11
Position Sheet. The ACPS will document proper evaluation, performance and restoration of the alignment, ensuring plant configuration control is maintained."
Perform OP- AA-1 08-106, "Equipment Return to Service," Revision 5, Step 4.3, which required that "if equipment will not be restored to the Equipment Line-up/Restoration position or the original condition, then another approved equipment status control mechanism shall be used to document equipment status (i.e. Equipment Status Tag, administrative clearance/tagout). Procedure OP-AA- 108-101, 'Control of Equipment and System Status,'
shall be used to document abnormal equipment configuration and shall be immediately applied following equipment restoration." In addition, neither Step 4.4.9 of OP-AA-108-106 which stated, "Applicable Operating Procedures are complete and any equipment line-ups directed to be completed by the Operating Procedures are completed," nor Step 4.4.14, which stated, 'The system/equipment has been walked down as appropriate to verify that it can be safely operated to fulfill its design function," were completed as required.
Perform OP-AA-109-101, "Clearance and Tagging," Revision 12, Step 10.2.1, which stated, "If a lift position is determined to be different from the normal lineup position for the present plant condition and not tracked by another C/O or procedure, then Shift Management shall be notified and equipment tracking initiated." In an interview between the inspectors and SRO 1, he stated that he thought the positions of 1DG160 and 1DG161 were being tracked via a procedure (CPS 3506.01P002). Licensee operations management stated that entering the procedure into the operations log was not the same as tracking via procedure.
Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the configuration control attribute of the Mitigating Systems Cornerstone and its objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to follow the above station procedures/work instructions resulted in the unavailability of the Division 2 EOG when it was relied upon for plant safety in a shutdown condition.
Significance: The inspectors evaluated the finding against the guidance of IMC 0609 Appendix G, Attachment 1, "Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings." The finding impacted the Mitigating Systems Cornerstone, specifically the Electric Power Availability Safety Function.
The finding represented a loss of system safety function for the EDGs for greater than its TS 3.8.2, Condition B.3, allowed outage time of Immediately which required a phase 2 Appendix G evaluation.
The phase 2 evaluation was conducted using IMC 0609 Appendix G, Attachment 3, and "Phase 2 Significance Determination Process Template for BWR during Shutdown." A Region Ill senior reactor analyst (SRA) completed the phase 2 evaluation and concluded that a phase 3, or detailed risk evaluation, would be needed to refine the phase 2 evaluation.
For the phase 2 evaluation, the applicable initiating event was a loss of offsite power (LOOP) event. The phase 2 evaluation focused on the 3 day exposure period in which both EDGs were unavailable and the plant was in plant operating state (POS) 1, with the reactor vessel head installed. The full exposure period for the finding is approximately 6 days. During the first 3 days, the Division 1 EOG remained available. The time to boil was approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and the time to uncover the core was approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, based on information provided by the licensee during the NRC's Management Directive (MD) 8.3 evaluation of the condition.
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To solve the phase 2 worksheet for a loss of offsite power in POS 1, the following assumptions were made:
The LOOP initiating event likelihood (IEL) was assigned a value of "3" consistent with an exposure time of less than 3 days. Although the actual time that both EDGs were unavailable was slightly over 3 days, the SRA determined that it would be overly conservative to use the IEL for an exposure time of 3 to 30 days.
The emergency AC power function was assigned a value of "O" because neither EDG was available.
The recovery of LOOP in 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> was assigned a value of "2" which is the maximum value used in phase 2 of the shutdown SDP. The function represents the recovery of AC power after battery depletion with successful injection from an AC-independent source.
The AC-independent injection before core damage (ACI) function was assigned a value of "3,"
the maximum value used in phase 2, to represent the potential to use an AC power independent source of injection such as the permanently installed diesel-driven fire pump.
The inspectors and the SRA determined that other plant-specific options to mitigate the event were more likely to be used by operators. The plant-specific options included the use of the Division 3 EDG to power Division 2 equipment or FLEX equipment.
The recovery of LOOP in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> was assigned a value of "1 ," the maximum value used in phase 2.
Recovery of the Division 2 EDG was assigned a value of "1," the maximum value used in phase 2. The inspectors determined that annunciator response and operating procedures would direct actions to restore the air receiver outlet valves to the open position.
Using the assumptions above, the two core damage sequences were solved with a value of "6" and "8," representing an overall delta core damage probability (CDP) in the range of E- 6.
The dominant core damage sequence is a LOOP event, no emergency AC power, successful AC-independent injection, but failure to recover offsite power in 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> (after battery depletion but before core damage).
A phase 3 SDP evaluation will be performed to further evaluate recovery of the Division 2 EDG, plant-specific mitigating system strategies such as the Division 3 cross-tie to Diivision 2, use of FLEX, and the recovery of offsite power. As a result the significance of this finding is to be determined (TBD).
Cross-cutting Aspect: The finding had a cross-cutting aspect in the Field Presence component of the Human Performance cross-cutting area, which states that Leaders are commonly seen in the work areas of the plant observing , coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly.
Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, the operators controlling the return to service of the Division 2 EDG were not properly coached to ensure that procedures required to maintain configuration control of the Division 2 EDG were carried out to ensure that it became and remained operable and available when relied upon for nuclear safety. (H .2) 13
Enforcement:
Apparent Violation: Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.
Clearance Order 139455 instructions required the performance of CPS 3506.01 P002, "Division 2 Diesel Generator Operations," Revision 3a, in conjunction with the removal of out-of-service tags on May 9, 2018.
Procedure OP- AA- 108- 103, "Locked Equipment Program," Revision 2, Step 4.1 .5, stated, "If plant conditions require a locked component to be positioned in a manner other than that indicated on the locked equipment checklist or approved procedure, then UNLOCK and REPOSITION equipment in accordance with OP- AA- 108- 101 , "Control of Equipment and System Status." Procedure OP-AA-108-101, "Control of Equipment and System Status,"
Revision 14, Step 4.1.1.1, stated, "Utilize an ACPS for aligning equipment outside of routine operations."
Procedure OP- AA- 108- 106, "Equipment Return to Service," Revision 5, Step 4.3, required that "if equipment will not be restored to the Equipment Line-up/Restoration position or the original condition, then another approved equipment status control mechanism shall be used to document equipment status (i.e. Equipment Status Tag, administrative clearance/tagout).
Procedure OP-AA-108-101 , 'Control of Equipment and System Status,' shall be used to document abnormal equipnnent configuration and shall be immediately applied following equipment restoration."
Procedure OP- AA- 108- 106, "Equipment Return to Service," Revision 5, Step 4.4.9, which stated, "Applicable Operating procedures are complete and any equipment line-ups directed to be completed by the Operating Procedures are completed."
Procedure OP- AA- 108- 106, "Equipment Return to Service, Revision 5, Step 4.4.14, stated, "The system/equipment has been walked down as appropriate to verify that it can be safely operated to fulfill its design function."
Procedure OP-AA-109-101 , "Clearance and Tagging," Revision 12, Step 10.2.1 stated, "If a lift position is determined to be different from the normal lineup position for the present plant condition and not tracked by another C/O or procedure, then the Shift Management shall be notified and equipment tracking initiated."
Technical Specification 3.8.2, "AC Sources-Shutdown," Condition B.3, states, in part, that an inoperable EDG be restored to an operable status immediately.
Between May 9 and May 17, 2018, the licensee apparently failed to:
Perform CPS 3506.01 P002, "Division 2 Diesel Generator Operations, Revision 3a, in conjunction with the removal of C/O 139455 as required by the C/O restoration instructions.
Perform OP- AA- 108- 103, "Locked Equipment Program," Revision 2, Step 4.3, valves 1DG160 and 1DG161 were normally locked open valves and an ACPS was not utilized to track valve status.
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Perform OP-M-108-106, "Equipment Return to Service," Revision 5, Step 4.3, when valves 1DG 160 and 1DG 161 were left in an abnormal position an approved equipment status control mechanism was not used to track equipment status.
Perform OP-M-108-106, "Equipment Return to Service," Revision 5, Step 4.4.9, when the equipment was declared operable the applicable operating procedure CPS 3506.01 P002 had not been completed and equipment line-ups directed to be completed by the operating procedures were not completed.
Perform OP-M-108-106, "Equipment Return to Service," Revision 5, Step 4.4.14, when the system was declared operable without being walked down.
Perform OP-M-109-101 , "Clearance and Tagging," Revision 12, Step 10.2.1, when the lift position was different from the normal lineup for the present plant condition and equipment tracking was not initiated.
Additionally, because the licensee was not aware of the EDG's inoperability the required action in TS 3.8.2, Condition 8 .3 was not followed.
Disposition: The disposition of this violation is TBD.
(5) Understand whether there were any deficiencies in operator training (both licensed and non-licensed operators) which contributed to the EOG unavailability and the failure to identify the condition across multiple operating shifts.
Observation I IP 93812 The inspectors reviewed training materials and had discussions with training management about the training program aspects and topics related to the event for the previous 2 years.
Training related to configuration control, including clearance and tagging processes used at CPS, was given in formal classroom training sessions during initial training for equipment operators (EOs), reactor operators (ROs), and SROs. Additional training on the implementation of configuration control procedures was given during initial qualifications and continuing training as "on-the-job" training. Passport was the software program used at CPS for implementing the clearance and tagging program. Similar to configuration control, the licensee gives initial training to operators on the use of Passport, and additional training related to Passport is considered on-the-job training . The inspectors did not identify any formal continuing training related to configuration control that was conducted in the previous 2 years, with the exception of one lesson related to clearance and tagging. The inspectors determined that the initial training material reviewed covered the requirements of station administrative procedures for configuration control. However, based on inspector discussions with SROs and members of the root cause team, the inspectors determined that SROs believed that component configuration was allowed to be tracked in the logs. This practice had been normalized at CPS. The practice of tracking configuration of components in the narrative log was not in accordance with any procedural guidance reviewed by the inspectors.
The knowledge gap between what was allowed by approved processes and procedures versus the actual methods and standards that CPS had been implementing was addressed in immediate station corrective actions that were implemented following this event. Corrective actions taken bv the licensee are discussed in Section (7) of this report.
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Additionally, the inspectors reviewed training materials and held discussions with training management related to training of equipment operators associated with plant tours and general area observations (i.e. "operator rounds"). The inspectors confirmed the equ ipment operators are given both initial and continuing training related to operator rounds performance standards. Inspector reviews and discussion with training management indicated a thorough training program related to operator rounds. 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.
Failure to Promptly Identify a Condition Adverse to Quality Cornerstone Significance Cross-Cutting Report Section Aspect Mitigating Systems Green [H. 12]- Human 93812- Special NCV 05000461 /2018050-02 Performance, Inspection Open/Closed Avoid Complacency On May 17, 2018, a Green finding and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," were self-revealed for the licensee's failure to promptly identify that the safety-related Division 2 EOG had its starting air receivers isolated, which was a condition adverse to quality that rendered the EOG inoperable and unavailable.
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Description:==
On May 11, 2018, at 2:30 a.m., the licensee declared the Division 2 EOG available following the removal of a clearance order supporting maintenance; at 8:00 a.m. on May 12, 2018, the licensee declared the Division 2 EOG operable. On May 14, 2018, the Division 2 EOG was put into a protected status for maintenance on the Division 1 EOG, when the Division 2 EOG would be the only source of emergency power available to the station. On May 17, 2018, at 3:03 p.m., an equipment operator on rounds found the two starting air receiver isolation valves, 1DG1 60 and 1DG161, in the closed position, which prevented starting air from reaching the Division 2 EOG, and the licensee declared the Division 2 EOG inoperable and unavailable.
After the licensee declared the Division 2 EOG available on May 11 , 2018, the licensee performed area rounds checks of the Division 2 EOG room at least once per shift. From May 11 through May 17, 2018, five different equipment operators performed 'C' area rounds checks, which included the 02 EOG room. Those five o perators had at least 12 opportunities to identify the problem before it was finally found. The licensee's failure to promptly identify the isolated valves resulted in the plant being in an elevated risk condition that was not allowed by plant procedures for three and one half days without their knowledge.
On May 17, 2018, at approximately 5:35 p.m., a sixth equipment operator identified that isolation valves 1DG160 and 1DG161 were in the closed position and reported them to the control room. The inspectors interviewed the operator that found the valves in the closed position and he stated that it was obvious that the valves were in the wrong position as soon as he entered the room. During a tour of the diesel room, the inspectors noted the relative large size of the air receiver isolation valves (2 inch ball valves with a handle approximately 6 inches long) that were located at knee level while standing on the platform adjacent to the air receivers and were also strapped in the closed position by long black plastic straps. The 16
inspectors also noted that there were two indications for air manifold pressures on each of the two local EOG panels in the Division 2 EOG room. At the time of the event these air manifold pressure gages read zero psig which was a clear indication that there was no starting air pressure available to the Division 2 EOG.
The inspectors conducted interviews with licensee personnel, reviewed the licensee's procedure for operator rounds, toured the Division 2 EOG room , and concluded that it was reasonably within the licensee's ability to identify the condition of the Division 2 EOG prior to return to service and during several opportunities following return to service, during normal equipment operator rounds . Considering all of the information reviewed, the inspectors determined that the licensee did not promptly identify thi s condition adverse to quality when it was reasonably within their ability to do so.
Normally, items found by the licensee while conducting operator rounds would be considered licensee identified in accordance with IMC 0612, "Issue Screening." However, Block 5 of IMC 0612, Appendix B, states that past experience, related precedents and the over-arching regulatory message should be considered when determining a finding's identification credit.
After careful consideration of the above items, the inspectors characterized the finding as self-revealing to align with the NRC's over-arching message regarding the need for improved operation department performance.
Corrective Actions: The licensee placed valves 1DG 160 and 1DG 161 into their correct position and performed a valve lineup of the Division 2 EOG system. Subsequent corrective actions included adding the EOG air start manifold pressure indications to the 'C' area rounds points log.
Corrective Action
Reference:
Action Request 4138790, "Division 2 DG Air Receiver Found Isolated Rounds," dated May 17, 2018 Performance Assessment:
Performance Deficiency: The inspectors determined that the licensee's failure to promptly identify the Division 2 EOG air start receiver isolation valves were not in the correct position was a performance deficiency.
Screening: The inspectors determined this issue was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Human Performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, the licensee, including multiple equipment operators, failed to promptly identify a condition adverse to quality, when multiple indications were available, that indicated the Division 2 EOG was inoperable and unavailable when it was being relied upon as a source of emergency power. As a result, the Division 2 EOG was not capable of responding to initiating events such as a loss of offsite power which placed the plant in an elevated risk condition.
Significance: The inspectors evaluated the significance of the finding 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) because all of screening questions were answered "no". Specifically, the failure to promptly identify the valves in the wrong position was not considered to be the proximate cause of the valves being in the wrong position.
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Cross-cutting Aspect: The finding had a cross-cutting aspect in the Avoid Complacency component of the Human Performance cross-cutting area, which states that individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools.
Specifically, equipment operators that toured the Division 2 EOG room on multiple occasions did not identify the latent issues that existed on the EOG and did not implement appropriate human performance tools to conduct intrusive tours of the EOG room with a questioning attitude and attention to detail. (H .12)
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that conditions adverse to quality, such as failures, deficiencies, deviations, and non-conformances are promptly identified.
Contrary to the above, from May 11 to May 17, 2018, the licensee failed to promptly identify a condition adverse to quality. Specifically, over the course of 6 days, the safety-related Division 2 EOG starting air receivers were isolated from the EOG air start motors, while it was relied upon for plant safety, which was a condition adverse to quality that rendered the EOG inoperable and unavailable.
Disposition: This violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policv.
Equipment Operator Rounds Points Inadequate Acceptance Criteria Cornerstone Significance Cross-Cutting Report Section Aspect Mitigating Systems Green [H.6] - Human 93812-Special NCV 05000461/2018050- 03 Performance, Inspection Open/Closed DesiQn MarQins On May 17, 2018, a Green finding and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," were self-revealed for the licensee's failure to include appropriate quantitative acceptance criteria for the Division 2 EOG parameters to ensure the Division 2 EOG could perform its safety function.
==
Description:==
On May 11, 2018, at 2:30 a.m., the licensee declared the Division 2 EOG available; at 8:00 a.m. on May 12, 2018, the licensee declared the Division 2 EOG operable. On May 17, 2018, at 3:03 p.m., an equipment operator on rounds in the field found the two air receiver isolation valves, 1DG160 and 1DG161 , in the closed position and the licensee declared the Division 2 EOG inoperable and unavailable. During the review into this issue ,
the licensee noted that the EOG air start manifold pressures were not a recorded value in the
'C' area round points performed by equipment operators. The inspectors were concerned that the 'C' area rounds points did not contain readily available information (air start manifold pressures) that would provide an indication of the EDGs ability to perform its safety function .
With the air start tanks isolated, the air start manifold pressures read O psig which would have provided an additional indication that the diesel was not available to start.
18
Corrective Action: On May 29, 2018, during the root cause investigation, the licensee revised the 'C' area rounds points to include EDG air start manifold pressure indications on the local EDG control panels.
Corrective Action
Reference:
Action Request 4138790, "Division 2 DG Air Receiver Found Isolated Rounds," dated May 17, 2018 Performance Assessment:
Performance Deficiency: The inspectors determined that the licensee's failure to include the Division 2 EDG air start manifold pressures in the 'C' area rounds points was a performance deficiency.
Screening: The inspectors determined this issue was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, by not including the air start manifold pressures in the operator round points, the licensee failed to recognize the Division 2 EDG was inoperable when it was being relied upon as a source of emergency power.
Significance: The inspectors evaluated the significance of the finding 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 failure to have the air manifold pressures in the rounds points was not considered to be the proximate cause of the valves being in the wrong position.
Cross-cutting Aspect: The inspectors determined the finding had a cross-cutting aspect of Design Margin in the Human Performance area, which states that the organization operates and maintains equipment within design margins and special attention is placed on maintaining safety related equipment (WP.2). Specifically, the operator round points which did not include the EDG air start manifold pressures failed to verify the EDG could maintain its safety function. (H.6)
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions and procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. The licensee established the 'C' area round points as the implementing procedure for logging Division 2 EDG parameters to ensure its ability to perform its intended safety function, an activity affecting quality.
Contrary to the above, prior to May 29, 2018, the licensee's 'C' area rounds points faiiled to include appropriate quantitative acceptance criteria for the Division 2 EDG parameters to ensure the Division 2 EDG could perform its safety function .
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
19
(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.
Observation I IP 93812 At the time of this inspection, the licensee had not completed their root cause evaluation; however, the inspectors reviewed the following immediate corrective actions taken by the licensee:
- Operations director memos were sent to the operations shift managers related to accountability and procedure use and adherence. These memos, which were required to be acknowledged by all operations department personnel and briefed by the operations shift managers, covered various administrative procedural requirements including:
procedure use and adherence, control of plant equipment, stop work criteria, operations decision making, and operability procedure requirements. The inspectors reviewed an operations director memo from May 18, 2018, "Issue Response Expectation for Clinton Operations Management." The inspectors also reviewed an operations director memo from May 23, 2018, "Manager Accountability for Performance." Interviews with operations department personnel indicated personnel were aware of the content of the memos.
- The operations director and operations department leaders conducted face-to-face discussions with each member of the operations department.
- Just-in-time training was given to all operations department staff on the requirements of HU-AA-104-1 0 1, "Procedure Use and Adherence," Revision 5. The inspectors' Interviews with operation's personnel indicated that they were aware of the requirements of HU- AA- 104- 101 .
- The licensee changed the clearance and tagging method to include signed restoration steps. Restoration steps were previously included as restoration instruction "notes."
These notes were expected to be completed as a procedure; however, the clearance order was allowed to be closed without documenting that these restoration steps had been completed. The inspectors reviewed several clearance orders and verified the lioensee's corrective action was being implemented.
- The licensee implemented a "Procedure-in-Progress" program for procedures that are not completed within one shift. The inspectors toured the control room and discussed the process with operators and observed it was being implemented.
- The licensee conducted a three day stand-down with all station personnel and covered case studies and learnings from the event. The inspectors reviewed the material covered during the stand-down and interviewed plant personnel, who were aware of the details of the stand-down. Revised the equipment operator rounds points to include logging emergency diesel generator starting air manifold pressures, located down-stream of the air tank isolation valves. The inspectors reviewed the revised 'C' area rounds points and verified operators were logging EOG air manifold pressures.
- Operations shift managers were reviewing logs and at least two completed procedures at the end-of-each shift. The inspectors requested to review any condition reports associated with these reviews and were informed that since this had been implemented, there had been no condition reports generated as a result of these shift manager reviews.
The inspectors conducted observations and interviews and concluded that the immediate corrective actions taken by the licensee were appropriate, and station personnel were qenerally aware of the EOG event, its causes, and corrective actions implemented.
20
The inspectors reviewed Operations Functional Area Audit Report, NOSA-CPS-17-08, dated October 3, 2017. The inspectors reviewed Configuration Control Self-Assessments conducted in 2017 and 2016, under ARs 4026575 and 2664637, respectively. The inspectors reviewed the 2017 Clinton Clearance and Tagging Self-Assessment conducted under AR 4047333. A review of the above items did not identify any gaps noted by nuclear oversight personnel or operations department staff that would have indicated similar iissues that lead to the cause the Division 2 EOG inoperability The inspectors reviewed the Operator Fundamentals Self-Assessment, dated January 29, 2018, under AR 4042011 . The inspectors noted that in Recommendation #1 the licensee stated, "Senior Leadership Team [SLT] observations are not entered in the Exelon Observation System in a thorough and consistent manner/ format making it difficult to assess operator fundamental performance related to SLT observations." However, the licensee also concluded that, "the CPS SLTis monitoring and reinforcing operator fundamentals ... and meaningful gaps to excellence were identified ... " The inspectors also noted that the number of observations documented in the second and third quarters of 2017 dropped to 45 from 138 total in 2015.
The inspectors did not identify any surveillance tests or maintenance activities that would have been able to identify the condition of the Division 2 EOG at an earlier time. However, as previously discussed, the inspectors did note that multiple (5) equipment operators had toured the Division 2 EOG room on several occasions (12) and had the opportunity to identify the condition of the EOG beinq inoperable.
(8) Determine whether recent internal and external operating experience involving configuration control, risk management and oversight of activities were appropriately evaluated and determine the adequacy of any corrective actions planned or completed.
Observation I IP 93812 There were two operating experience cases that were immediately relevant and available to the licensee. The first was an external operating event that occurred at Grand Gulf in September 2016. In this event alternate decay heat removal was being relied upon by the licensee as a second source of decay heat removal required by the TS. However, cooling to the alternate decay heat removal system had been tagged out-of-service for several weeks.
The licensee was made aware of this event through an industry communication and NRC Information Notice 2018-03, "Operating Experience Regarding Failure To Meet Technical Specification Requirements For Changing Plant Conditions," dated February 26, 2018. This event was discussed with plant management at the Plan of the Day meeting on April 23, 2017. The licensee addressed the NRC Information Notice with AR 4108876, "OPEX: IN 2018- 03 Failure To Meet TS For Change Conditions," dated February 27, 2018.
The due date for the licensee's response was not until July 13, 2018.
The second was an internal operating event that occurred at Clinton Station between May 24 and September 22, 2016.
On September 22, 2016, when an area operator was on rounds, the position of CO2 isolation valve to the generator exciter, 1CO609, was questioned when the operator observed that the valve was unlocked. Further investigation determined that 1CO609 was closed with a required position of locked open. A review of controlling documents determined that there was no open documentation controllinq this valve for its current position. A line up was 21
completed and 1CO609 was restored to its required locked open position. An evaluation was performed to determine the cause of 1CO609 being left in a position different from its required position. The review concluded that the last time 1CO609 was manipulated was in accordance with C/O 131019 which was hung to support generator inspections during C1R16.
Clearance Order 131019 was removed on May 24, 2016, with the position of 1CO609 left in the closed position (per C/O restoration position) and was required to be restored per CPS 3213.01 P001 , "Placing Turbine Generator Exciter CO2 System in Standby,"
Section 8.27, as identified in the clearance order special instructions under the restoration instruction.
The licensee determined that the operators failed to follow OP- AA- 108- 103, "Locked Equipment Program," Revision 2. Specifically, upon clearing of out-of-service tags associated with C/O 131019 valves 1CO609 and 1CO001 were left in the closed position which was abnormal from the required position. Valve 1CO609 was a locked valve left in an abnormal condition and the procedural requirements of OP- AA-108- 103 when a locked valve was left in an abnormal position were not followed.
The licensee's 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 3506.01 P002 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 which contributed to the EOG air receiver valves being left in the wrong position.
Observation- Licensee Identified Failure to Follow Procedure I IP 93812 The licensee identified a Green finding for the failure to follow licensee procedure OP- AA- 103, "Locked Equipment Program," Revision 2. Specifically, the licensee failled to track the status of a locked valve that was left in an abnormal position in accordance with the procedural requirements.
On September 22, 2016, when an area operator was on rounds, the position of CO2 isolation valve to the generator exciter, 1CO609, was questioned. The inspectors gave the licensee identification cred it for finding this valve out of position, even though it had been out of position for several months, because the valve was about 10 feet in the air and the valve position was not identifiable from the ground. The operator noticed the valve was not locked, which was difficult to see from the ground, and questioned its position. Further investigation determined that 1CO609 was closed with a required position of locked open. A review of controlling documents determined that there was no open documentation controlling this valve for its current position. A line up was completed and 1CO609 was restored to it s required locked open position. An evaluation was performed to determine the cause of 1CO609 being left in a position different from its required position. The review concluded that the last time 1CO609 was manipulated was in accordance with C/O 131019 which was hung to support generator inspections during C1R16. Clearance Order 131019 was removed on May 24, 2016, with the position of 1CO609 left in the closed position (per C/O restoration 22
position) and was required to be restored per CPS 3213.01 P001 , "Placing Turbine Generator Exciter CO2 System in Standby," Section 8.27, as identified in the clearance order special instructions under the restoration instruction.
The licensee determined that the operators failed to follow OP-M-108-103, "Locked Equipment Program," Revision 2. Exelon procedure OP- AA- 108- 103, "Locked Equiipment Program," Revision 2, Step 4.1.5, stated, "If plant conditions require a locked component to be positioned in a manner other than that indicated on the locked equipment checklist or approved procedure, then UNLOCK and REPOSITION equipment in accordance with OP-M-108-101 , 'Control of Equipment and System Status."' Valves 1DG160 and 1DG161 were normally locked open valves. Procedure OP- M - 108- 101 , "Control of Equipment and System Status," Step 4.1.1.1, stated, "Utilize an ACPS [abnormal component positioning sheet] for aligning equipment outside of routine operations." Specifically, upon clearing of out-of-service tags associated with CO 131019 valves 1CO609 and 1CO00 1 were left in the closed position which was abnormal from the required position. Valve 1CO609 was a locked valve left in an abnormal condition and an ACPS was not used to track the position of the valve.
Screening: The inspectors determined the performance deficiency was more than minor because it could reasonably be viewed as a precursor to a significant event. Specifically, the failure to effectively correct the above performance deficiency regarding locked equipment left in an abnormal condition eventually resulted in the unavailability of the Division 2 EOG when it was relied upon for plant safety in a shutdown condition.
Significance: The finding affected the Mitigating Systems Cornerstone and was screened in accordance with IMC 0609,. Appendix F," Table 1.2.1., which was answered "no." The inspectors determined that Step 1.4.2 was answered no and therefore the finding screened as Green.
Corrective Actions: The licensee's corrective action, at the time, was to put the valve into its correct position and put out a Daily Order, which was good September 30 through October 3, 2016, that discussed the requirements for tracking the status of plant equipment.
The licensee documented this event in AR 2718753, "EOID: 1CO609, 1coon Tank Outlet Valve Found Open," September 22, 2018.
Enforcement: The inspectors did not identify a violation of regulatory requirements associated with this finding. The equipment associated with this finding was non-safety related.
EXIT MEETINGS AND DEBRIEFS The inspectors confirmed that proprietary information was controlled to protect from public disclosure. No proprietary information was documented in this report.
- On June 29, 2018, the inspectors presented the initial Special Inspection results to Mr. T. Stoner, Clinton Power Station, Site Vice President and other members of the licensee staff during an interim exit meeting.
- On August 3, 2018, the inspectors presented the final Special Inspection results to Mr. T. Stoner, Clinton Power Station, Site Vice President and other members of the licensee staff during a final exit meeting.
23
THIRD PARTY REVIEWS None.
DOCUMENTS REVIEWED 93812- Special Inspection Paragraph (1)
- Control Room Logs May 5 through May 18, 2018
- AR 04150624; NRCID: C1R18 Risk Log Entries Inconsistent; 06/26/2018
- AR 04150906; Log Discrepancies Found During NRC SIT; 06/27/2018 Paragraph (2)
- C1R18 Shutdown Safety Management Program Safety Analysis; 04/09/2018 Paragraph (3)
- Root Cause Charter for the Event Associated with IR 4138790; Division 2 DG Air Receivers Found Isolated during Rounds; 05/17/2018 Paragraph (4)
- HU- AA- 104- 101 ; Procedure Use and Adherence; Revision 5 Paragraph (6)
- AR 04151037; Delete CPS 1409.01 Section 8.5-lt Is Out of Date; 06/27/2018
- CO 00139455, Checklist 4; C 1R 18-4.16kV Bus 181 Outage (AP- 181)
- CPS 1052.01; Conduct of System Lineups; Revision 9a
- CPS 1401 .09; Control of System and Equipment Status; Revision 9d
- CPS 1401 .09; Control of System and Equipment Status; Revision 9e
- CPS 3506.01 P002; Division 2 Diesel Generator Operations; Revision 3a
- CPS 3506.01 P002; Division 2 Diesel Generator Operations; Revision 3b
- ER- AA-31 O; lmplementatiion of the Maintenance Rule; Revision 11
- OP-AA-10; Clearance and Tagging Process Description; Revision 4
- OP-AA- 108- 103; Locked Equipment Program; Revision 2
- OP-AA-108-105; Equipment Deficiency Identification and Documentation; Revision 11
- OP- AA- 108- 106; Equipment Return to Service; Revision 5
- OP- AA- 108- 115; Operab1ility Determinations (CM- 1); Revision 20
- OP-AA-109-101; Clearance and Tagging; Revision 12
- OP-AA-11 1-101; Operating Narrative Logs and Records; Revision 18
- OP- CL- 108- 101- 1003; Operations Department Standards and Expectations; Revision 37
- OU-AA-103; Shutdown Safety Management Program; Revision 20 Paragraph (7)
- Unit 01 Standing Order 2018-06; Prerequisite Steps in Operating Procedures Directing Line-ups; 06/15/2018 24
- Unit 01 Standing Order 2018-03 ; Configuration Control Event IR# 04138790 ; 05/18/2018 Paragraph (8)
Nuclear Plant Plan of the Day Package, dated 04/13/201 25
From: Kozak, Laura Sent: Thu, 13 Sep 2018 21 :26 :03 +0000 To: Pelke, Pau l;Skokowski, Richard; Lambert, Kenneth;Stoedter, Karla;Sanchez Santiago, Elba;Sargis, Danie l Cc: Ph il lips, Charles;Hanna, John;Louden, Patrick;Lara, Julio;M itman, Jeffrey
Subject:
Clinton SERP package Please see attached SERP package for a SERP on 9/20 for the Clinton EOG issue
From : Mitman Jeffrey To : Kozak Laura Subject : Clinton Post SERP Date: Thursday, September 20 , 2018 5 :02:43 PM (b )(5)
I'll post the latest model, results spreadsheet and a corrected presentation on SharePoint before going home ton ight. I'll be back in on Monday morning. If you 're working tomorrow and want to talk, give me a call on my cell phone . I f (b)(6)
Jeff Mitman
Note to requester: The attachment to this email has been withheld in its entirety From: Mitman Jeffrey under FO IA Ex. B5 (deliberative To : Kozak Laura process privilege).
Subject : Clin ton Risk Results.pd!
Date: Thursday, September 20, 2018 1:39:23 PM Attachments: Clinton Risk Results.Rdf I squeezed the spreadsheet risk resu lts onto the attached 17X11 pdf. I may be of use to you.
Jeff
l(b)(5)
From : Kozak Laura To : Pe Ike Paul: Lambert Kenneth Subject : Clinton SERP Date: Thursday, September 20, 2018 1:36:00 PM Attachments: Cli!llil!l.lnop Both EDGs SD SERP 09-20-18 (2).PJID.
Jeff Mitman , ORA, intends to discuss some of the slides in this presentation at the SERP meeting today.
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- Div. 2 EOG opNSPS opDiv. 2
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Version Date: 07-23-2018 Pre-Decisional 24
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From : Kozak Laura To : west Steven : Lara Julio : Louden Patrick : Stoedter Karla: Riemer Kenneth : Cameron Jamnes ; ~
Santiago Elba Subject : Excerpts from Clinton loss of AC proced ure regarding declaring ELAP, exiti ng t he procedure, and high assura nce Date: Thursday, September 20 , 2018 10:58:00 AM Attachments : imaae_O_OJ .ona imaaeoo2 ona FYI based on our discussion. Two separate re levant sections below. Let me know if you would like the entire procedure.
Laura (b)(5)
(b)(5)
From : Kozak Laura To : Louden Patrick: Stoedter Karla : Riemer Kenneth : Sanchez Santiago Elba Cc : Lara Julio: Hanna John Subject : FW : Clint on both EDGs Unavailable during Shutdown SERP Presentation Date: Thursday, Sept ember 20, 2018 6:23:00 AM Attachments: Clinton lnop Both EDGs SD SERP 09-20-18 (2\ .pptx From: Mitman, Jeffrey Sent: Wednesday, Se ptem ber 19, 2018 9:27 PM To: Kozak, La ura <Laura.Kozak@ nrc.gov>; Fong, CJ <CJ .Fong@nrc.gov>; Felts, Russell
<Russel l. Fe lts@ nrc.gov>; Fran ovich, M ike <Mike.Fra novic h@nrc .gov>
Subject:
Clin ton both EDGs Unavai lable duri ng Shu tdown SER P Presentat ion These are the slides we intend to use during Thursday's SERP. They may be modified slightly based on review comments .
Because on the limited time available , we only intend to cover Slides 3 throug h 7 during the meeting . These slides discuss:
- Conservatisms
- Non-conservatisms
- Risk results
- Sensitivity case results
- Dominant sequences The rest are intended as supplemental/background information.
Jeff Mitman
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Version Date: 07-23-2018 Pre-Decisional 24
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From: ~
To : M*tman ,leffrey
Subject:
previous example of low/experience training Date: Thursday, September 20, 2018 3:47:00 PM Attachments : image-001.pllg (b )(5)
From: Kozak Laura To : Mitman Jeffrey Subject : question Date: Thursday, September 20 , 2018 12:06:00 PM While briefing the RA, l(b)( 5) l(b)(5)
Laura
From : Stoedter Karla To : Cameron Jamnes: Riemer Kenneth Subject : RE: Clinton EOG information Date: Thursday, September 20, 2018 1:37:00 PM (b )(5)
(b )(5)
..._ __, We can talk more when I am in the region .
From: Camero n, Jamnes Sent: Thursday, September 20, 2018 11:28 AM To: Stoedter, Karla <Karla.Stoedter@nrc .gov>; Riemer, Kennet h <Kenneth.Riemer@nrc.gov>
Subject:
RE : Clinton EDG information (b)(5)
From: Stoedter, Kar la Sent: Thursday, September 20, 2018 10:28 AM To: Cameron, Ja mnes <Jamnes.Cameron@nrc gov>; Ri emer, Kennet h <Kenneth Riemer@nrc.gov>;
West, St even <Steven .West@nrc.gov>
Subject:
Clinton EDG information The IFRB/SERP worksheets and the SIT report (which contains the documented PD and apparent violation ) are attached for your convenience . Let us know if you have further questions.
Karla
From: Kozak Laura To : Mitman Jeffrey Subject : RE: Clinton Update Date: Thursday, September 20 , 2018 7 :34 :00 AM When you get a chance can you call me to go over the sensitivity cases?
Thanks Laura From: M itman, Jeffrey Sent: W ednesday, Se ptem ber 19, 2018 9 :33 PM To: Ko za k, La ura <Laura.Kozak@ nrc.gov>
Subject:
Clinto n Upda t e I've put the "final " model on SharePoint. I've updated the risk results Excel Spreadsheet as well as the punch list. I sent the presentation to you and my management under separate email. Comments are always welcome.
Jeff Mitman
From : --.....
To: l!lllral!...lof SubJ4Kt; Load Siled - tima tritil:al actJon Frid;rr, Se:p4ember21 . 2018 12;41;S9 Pi4 Jeff Th is information ls from an Inspection a couple of years ago but I th ink it probably hasn't changed. ,._(_b_)_(_5_)_________________________.
Laura (b )(5)
From : Kozak Laura To : Mitman Jeffrey Subject : My thoughts on Clinton"s comments Date: Friday, September 21, 2018 11:15:00 AM Attachments: CPS comments SRA QfilS[)ectives.doc)(
Jeff I wrote up my views on Clinton 's comments that were provided in the email last week.
There has been discussion about the email in the reg ion and I provided many of these comments verbally but wanted to write down my thoughts. I am going to send this to regional staff and management also.
This, along with your HFE task analysis , should help draft the preliminary determination letter.
Laura
SRA review of CPS comments on the Detailed Risk Evaluation CPS Comment The DG1 B Recovery HEP is estimated to be well over an order of magnitude high given the plants need to restore the DG and the available time.
SRA Review (b )(5)
(b )(5)
CPS Comment Not crediting two alternate RPV depressurization methods leads the dominant sequences to be approximately an order of magnitude high.
SRA Review (b)(5)
CPS Comment Estimates of the SPAR-H inputs for calculating HEPs produces conservative HEPs that may be an order of magnitude high.
SRA Review CPS Comment Providing very limited credit for the use of RCIC and HPCS leads the dominant sequences to be high by approximately a factor two.
SRA Review
(b)(5)
CPS Comment The LOOP initiating event frequency includes events that may not be appropriate for the con ditions examined, resulting in a frequency that could over-estimated by as much as 29%.
SRA Review (b)(5)
From: Kozak Laura To : Louden Patrick : Lara Julio: stoedter Karla : Sanchez Santiago Elba : Phillips Charles Subject : My thoughts on Clinton"s emai led comments on the in-process risk evaluation Date: Friday, September 21, 2018 11 :23 :00 AM Attachments: CPS comments SRA QfilS[)ectives.doc)(
Last week Clinton emailed us their comments on our risk evaluation _ At the end of their document, they summarize the comments. I drafted my thoughts on their summarized comments in the attached file.
This will help us begin to draft the preliminary determination letter.
Please let me know if this is helpful or you have any questions. Also feel free to share with others in the region who may be interested.
SRA review of CPS comments on the Detailed Risk Evaluation CPS Comment The DG1 B Recovery HEP is estimated to be well over an order of magnitude high given the plants need to restore the DG and the available time.
SRA Review (b)(5)
(b)(5)
CPS Comment Not crediting two alternate RPV depressurization methods leads the dominant sequences to be approximately an order of magnitude high.
SRA Review (b)(5)
CPS Comment Estimates of the SPAR-H inputs for calculating HEPs produces conservative HEPs that may be an order of magnitude high.
SRA Review (b)( 5)
~r-.::i 1.,;omment Providing very limited credit for the use of RCIC and HPCS leads the dominant sequences to be high by approximately a factor two.
SRA Review
(b)(5)
CPS Comment The LOOP initiating event frequency includes events that may not be appropriate for the conditions examined, resulting in a frequency that could be over-estimated by as much as 29%.
SRA Review (b)(5)
From: Kozak Laura To : Sanchez Santiago Elba Subject : one other question Date: Friday, September 21, 2018 10:56:50 AM Hi Elba I have another question - again not urgent.
Thanks Laura
From: Kozak Laura To : Mitman Jeffrey Subject : RE: Clinton Post SERP Date: Friday, September 21, 2018 8:07:00 AM From: Mitman, Jeffrey Sent: Thursday, September 20, 2018 5:03 PM To: Ko za k, La ura <Laura .Kozak@ nrc.gov>
Subject:
Clinton Post SERP (b)(5)
I'll post the latest model, results spreadsheet and a corrected presentation on SharePoint before going home tonight. I'll be back in on Monday morning. If you're working tomorrow and want to talk, give me a call on my cell phone.! I J ~)(6L Jeff Mitman
From: Stoedter Karla To: Kozak Laura: Tesar Daniel Cc: Dickson Billy
Subject:
RE: Draft "One Pager" Date: Friday, September 21, 2018 7:15:54 AM
- Dan, Thanks for putting this together. Your initial draft looked good, but I had a few comments for consideration/addition:
- 1) The contact should be me instead of Billy
- 2) (b)(5) 3)
Thanks again, Karla From: Kozak, Laura Sent: Thursday, September 20, 2018 12:49 PM To: Stoedt er, Ka rla <Karla.Stoedt er @nrc.gov>
Subject:
FW: Draft "One Pager" From: Tesar, Daniel Sent: Thursday, September 20, 2018 12:31 PM To: Dickson, Billy <Bil ly,Dickson@nrc gov>; Kozak, Laura <Laura,Kozak@nrc,gov>
Subject:
Draft "One Pager" Team ,
Please see attached draft of the one pager. There is more that I wanted to add, but I ran out of room.
I guess the whole point of a one pager is to not put everything .. .. © Comments and feedback are greatly appreciated !!
- Thanks, Dan
From: Kozak Laura To: Lara Julio Subject : RE: My thoughts on Clinton"s emailed comments on the in-process risk evaluation Date: Friday, September 21, 2018 12:12:50 PM doable but sounds li ke a different one pager.
(b )(5)
Ta lked with Karla and shared these thoughts too. Along with my counterpart in DIRS and of course, with Jeff.
From: La ra, Julio Sent: Friday, September 21, 2018 12:46 PM To: Koza k, Laura <Laura.Kozak@nrc.gov>; Stoedter, Karla <Ka rla.Stoedter@nrc.gov>
Subject:
Fw: My thoughts on Clinton's emailed comments on the in- process risk evaluation Ill review in detail monday.
We need to include strategic key messages in the 1-pager focusing on clinton views in this doc plus address internal thoughts such as expressed during serp. Is monday doable?
I th ink there is value in trying to get this document into senior managers hands as soon as possible to get ahead of the communications.
Thx Have a great weekend.
JL From: Kozak, Laura Sent: Friday, September 21, 2018 11:23:47 AM To: Louden, Patrick; Lara, Julio; Stoedt er, Karla; Sanchez Santiago, Elba; Phil lips, Charles
Subject:
My thoughts on Clinton's emailed comments on the in-process risk evaluation Last week Clinton emailed us their comments on our risk evaluation. At the end of their document, they summarize the comments. I drafted my thoughts on their summarized comments in the attached file.
This will help us begin to draft the preliminary determination letter.
Please let me know if this is helpful or you have any questions. Also feel free to share with others in the region who may be interested.
From : Kozak Laura To : Giessner John Subject : FW: My thoughts on Clin ton"s emailed comments on the in -process risk evaluation Date: Sunday, September 23, 2018 10:03:37 AM Attachments: CPS comments SRA QfilS[)ectives.doc)(
Just FYI From: Kozak, Lau ra Sent: Friday, September 21, 2018 12:24 PM To: Louden, Patrick <Patrick .Louden@nrc .gov>; Lara, Ju lio <Jul io.Lara@n rc.gov>; Stoedter, Kar la
<Ka rl a.Stoedt er@nrc.gov>; Sa nchez Sa nti ago, Elba <E lba.SanchezSant iago@nrc.gov>; Phill ips, Charles <Ch arles. Phillips@n rc.gov>
Subject:
My tho ughts on Clinto n's emai led comme nts on the in-process ri sk eva luat io n Last week Clinton emailed us their comments on our risk evaluation. At the end of their document, they summarize the comments. I drafted my thoug hts on their summarized comments in the attached file.
This will help us begin to draft the preliminary determination letter.
Please let me know if this is helpful or you have any questions . Also feel free to share with others in the region who may be interested.
SRA review of CPS comments on the Detailed Risk Evaluation CPS Comment The DG1 B Recovery HEP is estimated to be well over an order of magnitude high given the plants need to restore the DG and the available time.
SRA Review (b)(5)
(b )(5)
CPS Comment Not crediting two alternate RPV depressurization methods leads the dominant sequences to be approximately an order of magnitude high.
SRA Review CPS Comment Estimates of the SPAR-H inputs for calculating HEPs produces conservative HEPs that may be an order of magnitude high.
SRA Review CPS Comment Providing very limited credit for the use of RCIC and HPCS leads the dominant sequences to be high by approximately a factor two.
SRA Review
(b )(5)
CPS Comment The LOOP initiating event frequency includes events that may not be appropriate for the conditions examined, resulting in a frequency that could be over-estimated by as much as 29%.
SRA Review (b )(5)
Note to requester: All attachments to this email have been redacted in its entiret under FOIA Ex. B5 deliberative recess rivile e .
From: Kozak Laura To: Biemer Kenneth
Subject:
FW: 1 hr crash course on SPAR-H (HRA/HEP)
Date: Monday, September 24, 2018 12:03 :00 PM Attachments: SPAR-H Shutdown Worksheets Generic x1sx Task 1 8 SPAR-H Step-by-Step Guidance IFjnal} pd(
Credit for recovery examples docx From: Kozak, Laura Sent: Su nday, September 23, 2018 10:11 AM To: Lara, Julio <J ulio.Lara @nrc.gov>
Cc: Hanna, John <John.Hanna @nrc.gov>; Louden, Patrick <Patrick.Louden@nrc.gov>; Stoedter, Karla
<Ka rla.Stoedter@nrc.gov>
Subject:
RE: 1 hr crash course on SPAR-H (H RA/HEP)
Sounds good wi ll do.
Just FYI - I attached the actual worksheet we use to ca lculate the HEPs for shutdown and a guidance document t hat is the "Step by Step Guidance" I also attached a document that gives several examples of the app lication of recovery that have some similarities to the current issue - was not sure if you were on original distribution There is also a specific NU REG on SPAR -H From: La ra, Julio Se nt: Su nday, September 23, 2018 9:31 AM To: Koza k, Laura <Laura.Kozak@nrc.gov>
Cc: Hanna, John <John Hanna@nrc gov>; Louden, Pat rick <Patrick Louden@nrc gov>
Subject:
1 hr crash course on SPAR-H (HRA/H EP)
- Laura, I like to increase my knowledge a bit more as it relates to the Clinton preliminary White.
Pat will be travelling out this week . Perhaps invite Karla if shes available.
Thx JL
From: Kozak Laura To: Sanchez Santiago Elba Subject : RE: Another request - not urgent Date: Monday, September 24, 2018 3:44:00 PM Attachments: image001 .ong Thanks again!
From: Sa nchez Santiago, Elba Sent: Monday, September 24, 2018 3:02 PM To: Koza k, Laura <Laura.Kozak@nrc.gov>
Subject:
RE: Anot he r request - not urgent
- Laura, Attached is a portion of a 1B diesel procedure that includes a list of the loads on the 1AP61 E MCC. I also reviewed the drawing for this MCC and noticed that not included on the list are:
- 2. Chem lab standby lighting
- 3. Diesel Gen 1B aux relays (for remote start/stop and auto start)
Let me know if you have any questions or need additional information.
- Thanks, Elba From: Kozak, Laura Sent: Thursday, September 20, 2018 4:09 PM To: Sanchez Santiago, Elba <Elba .SanchezSantiago@nrc.gov>
Subject:
Another request - not urgent Elba Thanks Laura
(b )(5)
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: Tesar Daniel Cc: stoedter Karla
Subject:
RE: Draft "One Pager" Date: Monday, September 24, 2018 1 :44:00 PM Attachments: Risk Comms Clinton PG Air.pptx Dan I made some significant changes but I don't know how to format this to make it look better.
Can you work with it more? See attached file.
I'd also like to delete the event tree and add the following section.
Key Messages (b)(5)
From: Tesar, Daniel Sent: Thursday, September 20, 2018 12:31 PM To: Dickson, Billy <Bil ly.Dickson@nrc.gov>; Kozak, Laura <Laura.Koza k@nrc.gov>
Subject:
Draft "One Pager"
- Team, Please see attached draft of the one pager. There is more that I wanted to add, but I ran out of room.
I guess the whole point of a one pager is to not put everything .... © Comments and feedback are greatly appreciated !!
- Thanks, Dan
(b)(5)
From: Kozak Laura To: Sanchez Santiago Elba Subject : RE: one other question Date: Monday, September 24, 2018 3:41 :39 PM Yes, exactly what I was looking for.
Thanks!
From: Sa nchez Santiago, Elba Sent: Monday, September 24, 2018 2:46 PM To: Koza k, Laura <Laura.Kozak@nrc.gov>
Subject:
RE: one other question Laura, (b)(5)
Let me know if this is what you were looking for.
-Elba From: Kozak, Laura Sent: Friday, September 21, 2018 10:57 AM To: Sanchez Sant iago, Elba <Elba SanchezSantiago@nrc.gov>
Subject:
one other quest ion Hi Elba I have another question - again not urgent.
Thanks Laura