RS-15-261, Concerns with Nrc'S Inappropriate Application of Significance Determination Process: Difference between revisions

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{{#Wiki_filter:4300 Winfield Road Warrenviue, IL 60555 ExeLon Generation
{{#Wiki_filter:4300 Winfield Road Warrenviue, IL 60555 ExeLon Generation,,
,, RS-15-261 September 30, 2015 U.S. Nuclear Regulatory Commission ATTN: Regional Administrator Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461  
RS-15-261 September 30, 2015 U.S. Nuclear Regulatory Commission ATTN: Regional Administrator Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461


==Subject:==
==Subject:==
Concerns with NRC's Inappropriate Application of Significance Determination Process  
Concerns with NRC's Inappropriate Application of Significance Determination Process


==References:==
==References:==
Line 29: Line 29:
: 2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Request for Extension to Submit an Appeal," dated September 9, 2015
: 2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Request for Extension to Submit an Appeal," dated September 9, 2015
: 3. Letter from P. L. Louden (U.S. NRC) to B. C. Hanson (Exelon Generation Company, LLC), "Request for 10-Day Extension to Submit Appeal Regarding White Finding Associated with the Division 3 Shutdown Service Water Pump," dated September 11, 2015 In Reference 1, the NRC provided the final significance determination of a preliminary finding related to the failure of the Division 3 Shutdown Service Water (SX) system pump to perform its intended safety function. Reference 1 stated that an appeal of the NRC's determination of significance for the identified White finding should be submitted within 30 days (i.e., by September 10, 2015). However, in Reference 2, Exelon Generation Company, LLC (EGC) requested a 10-day extension to allow additional time to evaluate the merits of an appeal for the basis of the White finding. The NRC approved EGC's request for a 10-day extension in Reference 3, which stated that any appeal of the White finding must now be submitted by September 20, 2015.
: 3. Letter from P. L. Louden (U.S. NRC) to B. C. Hanson (Exelon Generation Company, LLC), "Request for 10-Day Extension to Submit Appeal Regarding White Finding Associated with the Division 3 Shutdown Service Water Pump," dated September 11, 2015 In Reference 1, the NRC provided the final significance determination of a preliminary finding related to the failure of the Division 3 Shutdown Service Water (SX) system pump to perform its intended safety function. Reference 1 stated that an appeal of the NRC's determination of significance for the identified White finding should be submitted within 30 days (i.e., by September 10, 2015). However, in Reference 2, Exelon Generation Company, LLC (EGC) requested a 10-day extension to allow additional time to evaluate the merits of an appeal for the basis of the White finding. The NRC approved EGC's request for a 10-day extension in Reference 3, which stated that any appeal of the White finding must now be submitted by September 20, 2015.
After further evaluation, EGC has elected not to appeal the White finding. EGC understands its responsibility for identifying components that will perform reliably in their operating environment.
After further evaluation, EGC has elected not to appeal the White finding. EGC understands its responsibility for identifying components that will perform reliably in their operating environment.
,'Affairs September 30, 2015 U.S. Nuclear Regulatory Commission Page 2 However, as discussed in Reference 2, EGC is concerned over the reasonableness of holding a licensee accountable for the actions of a qualified vendor manufacturing components under its own 10 CFR 50, Appendix B, quality assurance program who supplies a component (i.e., Division 3 SX pump) to a licensee that subsequently fails through no fault of the licensee. The pump failure was caused by a deficient hardface application, which ultimately caused failure of the bushing because cooling water flow was blocked. The hardface application technique (i.e.
 
September 30, 2015 U.S. Nuclear Regulatory Commission Page 2 However, as discussed in Reference 2, EGC is concerned over the reasonableness of holding a licensee accountable for the actions of a qualified vendor manufacturing components under its own 10 CFR 50, Appendix B, quality assurance program who supplies a component (i.e.,
Division 3 SX pump) to a licensee that subsequently fails through no fault of the licensee. The pump failure was caused by a deficient hardface application, which ultimately caused failure of the bushing because cooling water flow was blocked. The hardface application technique (i.e.
hardface thickness) is below the level of detail of the design and it is not reasonable for EGC to specify in a procurement specification.
hardface thickness) is below the level of detail of the design and it is not reasonable for EGC to specify in a procurement specification.
Notwithstanding the above, EGC disagrees with the NRC's conclusion. Nonetheless, EGC has decided not to further appeal, in part, due to EGC's informed view that the NRC's decision was based on totality of the circumstances present in this matter as opposed to intending to establish a requirement where a licensee is expected to specify such a level of detail to the vendor in a procurement document for a safety-related structure, system, or component. Such a requirement by the NRC would be beyond its own precedent and regulatory guidance.
Notwithstanding the above, EGC disagrees with the NRC's conclusion. Nonetheless, EGC has decided not to further appeal, in part, due to EGC's informed view that the NRC's decision was based on totality of the circumstances present in this matter as opposed to intending to establish a requirement where a licensee is expected to specify such a level of detail to the vendor in a procurement document for a safety-related structure, system, or component. Such a requirement by the NRC would be beyond its own precedent and regulatory guidance.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Glen Kaegi at (630) 657-2811.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Glen Kaegi at (630) 657-2811.
cc: NRC Document Control Desk NRC Senior Resident Inspector - Clinton Power Station Illinois Emergency Management Agency - Division of Nuclear Safety}}
                                  ,'Affairs cc:     NRC Document Control Desk NRC Senior Resident Inspector Clinton Power Station
                                          -
Illinois Emergency Management Agency Division of Nuclear Safety
                                                  -}}

Revision as of 07:12, 31 October 2019

Concerns with Nrc'S Inappropriate Application of Significance Determination Process
ML15273A122
Person / Time
Site: Clinton Constellation icon.png
Issue date: 09/30/2015
From: Fewell J
Exelon Generation Co
To:
Document Control Desk, Region 3 Administrator
References
EA-15-064, IR 2015009, RS-15-261
Download: ML15273A122 (2)
v • d • e


Text

4300 Winfield Road Warrenviue, IL 60555 ExeLon Generation,,

RS-15-261 September 30, 2015 U.S. Nuclear Regulatory Commission ATTN: Regional Administrator Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Concerns with NRC's Inappropriate Application of Significance Determination Process

References:

1. Letter from C. D. Pederson (U.S. NRC) to B. C. Hanson (Exelon Generation Company, LLC), "Final Significance Determination of a White Finding with Assessment Followup and Notice of Violation; NRC inspection Report No.

05000461/2015009; Clinton Power Station," dated August 11, 2015

2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Request for Extension to Submit an Appeal," dated September 9, 2015
3. Letter from P. L. Louden (U.S. NRC) to B. C. Hanson (Exelon Generation Company, LLC), "Request for 10-Day Extension to Submit Appeal Regarding White Finding Associated with the Division 3 Shutdown Service Water Pump," dated September 11, 2015 In Reference 1, the NRC provided the final significance determination of a preliminary finding related to the failure of the Division 3 Shutdown Service Water (SX) system pump to perform its intended safety function. Reference 1 stated that an appeal of the NRC's determination of significance for the identified White finding should be submitted within 30 days (i.e., by September 10, 2015). However, in Reference 2, Exelon Generation Company, LLC (EGC) requested a 10-day extension to allow additional time to evaluate the merits of an appeal for the basis of the White finding. The NRC approved EGC's request for a 10-day extension in Reference 3, which stated that any appeal of the White finding must now be submitted by September 20, 2015.

After further evaluation, EGC has elected not to appeal the White finding. EGC understands its responsibility for identifying components that will perform reliably in their operating environment.

September 30, 2015 U.S. Nuclear Regulatory Commission Page 2 However, as discussed in Reference 2, EGC is concerned over the reasonableness of holding a licensee accountable for the actions of a qualified vendor manufacturing components under its own 10 CFR 50, Appendix B, quality assurance program who supplies a component (i.e.,

Division 3 SX pump) to a licensee that subsequently fails through no fault of the licensee. The pump failure was caused by a deficient hardface application, which ultimately caused failure of the bushing because cooling water flow was blocked. The hardface application technique (i.e.

hardface thickness) is below the level of detail of the design and it is not reasonable for EGC to specify in a procurement specification.

Notwithstanding the above, EGC disagrees with the NRC's conclusion. Nonetheless, EGC has decided not to further appeal, in part, due to EGC's informed view that the NRC's decision was based on totality of the circumstances present in this matter as opposed to intending to establish a requirement where a licensee is expected to specify such a level of detail to the vendor in a procurement document for a safety-related structure, system, or component. Such a requirement by the NRC would be beyond its own precedent and regulatory guidance.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Glen Kaegi at (630) 657-2811.

,'Affairs cc: NRC Document Control Desk NRC Senior Resident Inspector Clinton Power Station

-

Illinois Emergency Management Agency Division of Nuclear Safety

-

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