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{{#Wiki_filter:NRC FORM 757 NRC MD 10.158 (3*2009) u.s. NUCLEAR REGULATORY COMMISSION NON-CONCURRENCE PROCESS SECTION A -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL TITLE OF DOCUMENT St. Lucie Inspection Report 05000389/2010003 DOCUMENT SPONSOR Mark Franke NAME OF NON-CONCURRING I NDIVIDUAL Walt Rogers D DOCUMENT AUTHOR D DOCUMENT CONTRIBUTOR TITLE Senior Reactor Analyst REASONS FOR NON-CONCURRENCE D DOCUMENT REVIEWER I ORGANIZATION DRSlEB2 ADAMS ACCESSION NO. SPONSOR PHONE NO. 404-997-4436 PHONE NO. 404-997-4619 ON CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance.
{{#Wiki_filter:NRC FORM NRC      FORM 757  757                                                                               u.s. NUCLEAR REGULATORY U.S. NUCLEAR  REGULATORY COMMISSION COMMISSION NRC MD NRC   MD 10.158 10158 (3-2009)
The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivties . ...1.. n d it;o VI s. ("\
(3*2009)
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NON-CONCURRENCE PROCESS SECTION A SECTION          A - TO
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                      - TO BEBE COMPLETED COMPLETED BY BY NON-CONCURRING        INDIVIDUAL NON-CONCURRING INDIVIDUAL TITLE OF TITLE      OF DOCUMENT DOCUMENT                                                                                               ADAMS ADAMS ACCESSION NO. NO.
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Inspection Report St. Lucie Inspection                  05000389/2010003 Reøort 05000389/2010003 DOCUMENT SPONSOR DOCUMENT            SPONSOR                                                                                            SPONSOR SPONSOR PHONEPHONE NO.
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Mark Franke Mark         Franke                                                                                                           404-997-4436 404-997-4436 NAME OF NAME      OF NON-CONCURRING          INDIVIDUAL NON-CONCURRING INDIVIDUAL                                                                            PHONE PHONE NO. NO.
\.A\+h D CONTINUED IN SECTION D SIGNATURE .. L r SUBMIT FORM TO DOCUMENT SPONSOR AND eOPY TO YOUR IMMEDIATE SUPERVISOR AND DIFFERING VIEWS PROGRAM MANAGER .' NRC FORM 757 (3-2009) Use ADAMS Template NRc'()06 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD 10.158 (3-2009) U.S. NUCLEAR REGULATORY COMMISSION NON-CONCURRENCE PROCESS TITLE OF DOCUMENT St. Lucie Inspection Report 0500038912010003 I ADAMS ACCESSION NO. SECTION B -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S SUPERVISOR (THIS SECTION SHOULD ONLY BE COMPLETED IF SUPERVISOR IS DIFFERENT THAN DOCUMENT SPONSOR.)
Walt Rogers                                                                                                                    404-997-4619 D      DOCUMENT AUTHOR DOCUMENT          AUTHOR          D    DOCUMENT CONTRIBUTOR DOCUMENT                        D    DOCUMENT REVIEWER DOCUMENT    REVIEWER        ~    ON ON CONCURRENCE TITLE TITLE                                                                    ORGANIZATION Senior Reactor Analyst                                                    DRS/EB2 IDRSlEB2 REASONS FOR NON-CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance. The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivtiesactiivties..
NAME Rebecca L. Nease TITLE Cbief, Engineering Brancb 2 ORGANIZATION Division of Reactor Safety. Region D COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER D I HAVE NO COMMENTS !ill I HAVE THE FOLLOWING COMMENTS I PHONE NO. 404-997-4530 I bave reviewed tbe attacbed documentation, and it appears tbat all parties bave acted in good faitb, to consider all views witb repsect to tbe subject of tbis non-concurrence.
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At issue is wbetber is is appropriate to use tbe sbutdown operations significnce determination process (SDP) or tbe at-power SDP for tbe described performance deficiency.
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While a conclusion was reacbed tbat sbutdown risk was not to be considered, it appears tbat tbis was not a consensus view among tbe staff in NRR and Region D. In addition, it appears tbat tbe guidance could bave supported eitber view, depending on wbicb part of tbe guidance was referenced.
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Tbis ambiguity does not speak well for our principals of good regulation, especially tbe principal of clarity. Having reviewed tbe documents attacbed berein, and read eacb view, eitber metbodology (sbutdown risk or at-power risk) appears to meet at least some parts oftbe guidance.
                                              *ke-  (plIO
However, in using sbutdown risk to conclude a bigber risk level, we would bave bad tbe opportunity (witbin tbe guidance) to send a strong message to tbe licensee tbat repeatedly entering a risk-signficant plant configuration to fIX tbe same or similar degraded condition is not in tbe interest of safety. I believe tbe confusing guidance bears revision to provide clarity to tbe process and to permit sucb latitide in egregious cases, sucb as tbis one. D CONTINUED IN SECTION D SIGNAfLr1l/l Ii v SUBMIT THIS PAGE TO DOCUMENT SPONSOR ". I I NRC FORM 757 (3-2009) Use ADAMS Template NRC-D06 PRINTED ON RECYCLED PAPER
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, NRC FORM 757 NR C M D10.158 (3-2009) TITLE OF DOCUMENT U.S. NUCLEAR REGULATORY COMMISSION I ADAMS ACCESSION NO. 8t Lucie Inspection Report 05000389/2010003 SECTION C -TO BE COMPLETED BY DOCUMENT SPONSOR NAME Mark Franke TITLE Branch Chief ORGANIZATION DRSlEB3 --------------------
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I PHONE NO. 404-997-4436 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised , as necessary, to reflect the final outcome of the non-concurrence process, i ncluding a complete d i scussion of how individual concerns were addressed.) The issue at the heart of this non-concurrence is whether it is appropriate to assess shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed seal line finding. I believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and NRR DIRS and DRA. On March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should not be used to evaluate this finding and stated that NRRlDRA did not believe this performance deficiency affected operations during shutdown conditions.
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Lois James referenced IMC 0609 , the RASP Handbook, and a review of past findings as the basis for this decision.
D CONTINUED CONTINUED IN  IN SECTION SECTION DD SIGNATURE SIGNATURE                                                                                                        DATE SUBMIT SUBMIT FORM FORM TOTO DOCUMENT
Her email of 3/3/2010 describes this argument and it is attached.
                                                      ~
Additional meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives.
DOCUMENT SPONSOR SPONSOR AND  AND COPY eOPY TO  TO YOUR YOUR IMMEDIATE IMMEDIATE SUPER
It became evident that a number of experienced staff, working with the same facts and using current guidance, came to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance Assessment Branch, expressed concern over the whether it was programmatically appropriate and consistent to use Appendix G for this finding considering that the finding occurred At-power.
                                                                                                                        .. L SUPERVISOR ISOR ANDAND Ji r          .'
On April 30, 2010, after considering all of the perspectives, John Lubinski (acting DRS director) determined that it was consistent with our process and practice to process to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment.
                                                                                                                                                  ~.
It would screen out per IMC 0609 Phase 1 screening.
DIFFERING DIFFERING VIEWS VIEWS PROGRAM PROGRAM MANAGER MANAGER NRC NRC FORM FORM 757 757 (3-2009)
To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation.
(3-2009)                                                                                                      ON RECYCLED PRINTED ON PRINTED    RECYCLED PAPER PAPER Use Use ADAMS ADAMS Template Template NRC-006 NRc'()06
We did not identify performance deficiencies associated with the licensee's shutdown operations or maintenance risk managment. (Reference Lubinski email 4/30110, attached).
 
Rani Franovich,Chief of Performance Assessment, agreed with this decision via email on 6/4/2010.
NRC FORM 757 NRC                                                                                                       NUCLEAR REGULATORY COMMISSION U.S. NUCLEAR 10.158 NRC MD 10.158 (3-2009)
I have reviewed this non-concurrence documentation in detail. It illustrates the numerous important arguments and counter-arguments that the staff discussed and highlights several areas for potential SDP guidance clarification.
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT                                                                                                       IADAMS ACCESSION NO.
Because I believe that these arguments were thoughtfully considered in the April 30 decision, I do not propose reversing that decision.
05000389/2010003 St. Lucie Inspection Report 0500038912010003 SECTION B - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S
The performance deficiency was not viewed to extend into the licensee's decisions to shutdown and repair. To address staff division and concerns over this, DIRS initiated an effort to examine whether changes were needed in NRC procedures to ensure clarity, reliability, and efficiency going forward. DIRS initiated an ROP feedback form to track this effort. (Reference Franovich email 6/4/10) I believe, on balance, that the decisions to treat this finding as an At-Power finding and to conduct a review of our guidance are in the interests of ROP reliability and clarity, which are in the the public interest.
                -                                                      INDMDUALS SUPERViSOR SUPERVISOR (THIS SECTION SHOULD ONLY BE            BE COMPLETED IF                           DIFFERENT THAN DOCUMENT SPONSOR.)
This path also provides for additional stakeholder participation and communication should SDP guidance revisions occur. D CONTINUED IN SECTION D 1';;Zb (;0 NON-CONCURRING INDIVIDUAL (To be completed by documerl sponsor when process is complete , i.e., after document is signed): D CONCURS o NON-CONCURS D W I THDRAWS NON-CONCURRENCE (L e., d i scontinues process) NRC FORM 757 (3-2009) Use ADAMS Template NRC-D06 c6 WANTS NCP FORM PUBLIC D WANTS NCP FORM NON-PUBLIC PRINTED ON RECYCLED PAPER Franke, Mark From: Sent: To:
IF SUPERVISOR IS DIFFERENT NAME Rebecca L. Nease TITLE                                                                                                                   PHONE NO.
Cbief, Engineering Brancb
: Chief, ORGANIZATION ORGANIZATION Branch 2                                                                                   I      404-997-4530 Division of Reactor Safety. Safety, Region IID COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER D       II HAVE HAVE NO COMMENTS
                !ill   II HAVE THE FOLLOWING COMMENTS I have bave reviewed the  tbe attacbed attached documentation, and it appears that tbat all parties have                  faitb, to consider all views bave acted in good faith, witb repsect to the with                  tbe subject of tbis this non-concurrence. At issue is whether wbetber is is appropriate to use the    shutdown operations tbe sbutdown significnce determination process (SDP) or the        tbe at-power SDP for tbethe described performance deficiency. While a conclusion reacbed tbat was reached        that sbutdown shutdown risk was not to be considered, it appears that      this was not a consensus view among the tbat tbis                                        tbe staff in NRR and Region II.          D. In addition, it appears tbat                         have supported eitber tbe guidance could bave that the                                    either view, depending on which  wbicb part of tbe the guidance was referenced. Tbis       This ambiguity does not speak well for our principals of good regulation, especially tbe         the principal of clarity.
Having reviewed tbe       the documents attacbed attached berein,              each view, eitber herein, and read eacb         either metbodology   (shutdown risk or at-power risk) methodology (sbutdown appears to meet at least some parts oftbe                                             shutdown risk to conclude a bigber of the guidance. However, in using sbutdown                             higher risk level, we would havebave hadbad tbe the opportunity (witbin (within tbe the guidance) to send a strong message to tbe the licensee tbat that repeatedly entering a risk-signficant plant configuration to fIX     fix tbe the same or similar degraded condition is not in tbe the interest of safety. I believe tbe   the confusing guidance bears revision to provide clarity to tbe         the process and to permit sucb such latitide in egregious cases, sucb         this such as tbis one.
D CONTINUED CONTINUED IN SECTION D       D Ii ~
SIGNAT E                                                                                                          DATE SIGNAfLr1l/l v
7/43//d
                                                                                                                          ". I     I SUBMIT THIS PAGE TO DOCUMENT SPONSOR NRC FORM FORM 757 (3-2009)                                     Use ADAMS Template NRC.006 NRC-D06                                   PRINTED ON RECYCLED PAPER
 
,     NRC FORM NRC     FORM 757 NRC MD10.158 NRC  MD 10158 (3-2009) 757                                                                                                        U.S.
U.S. NUCLEAR NUCLEAR REGULATORY REGULATORY COMMISSION COMMISSION (3-2009)
NON-CONCURRENCE PROCESS NON~ONCURRENCEPROCESS TITLE OF TITLE      OF DOCUMENT DOCUMENT                                                                                                                                  IADAMS ADAMS ACCESSION ACCESSION NO. NO.
St Lucie 8t    Lucie Inspection Inspection Report    Report 05000389/2010003 05000389/2010003
                                                                                          -----------------------------------~I-------------------
SECTION CC - TO SECTION                      -      BE COMPLETED TO BE    COMPLETED BY          DOCUMENT SPONSOR BY DOCUMENT            SPONSOR NAME
                                                                                            -------------
NAME Mark Franke Mark        Franke TITLE TITLE                                                                                                                                                          PHONE PHONE NO.NO.
Branch Chief Branch          Chief                                                                                                                                                 404-997-4436 ORGANIZATION I        404-997-4436 ORGANIZATION DRS/EB3 DRSlEB3
  -ACTIONS  - -TAKEN ACTIONS TAKEN
                            - -TO      -ADDRESS
                                          -
TO ADDRESS      NON-CONCURRENCE (This NON-CONCURRENCE            (This section section should should bebe revised revised,, as necessary, to as necessary,  to reflect reflect the the final final outcome outcome ofof the the non-concurrence process, non-concurrence                  process, including including aa complete complete discussion discussion ofof how  individual concerns how individual    concerns were were addressed.)
addressed.)
The issue at The                  at the heart of this     this non-concurrence non-concurrence is whether it           it is appropriate to assess shutdown shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed                    failed seal line finding.
II believe believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and  and NRR DIRS and DRA.
On March On    March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix G,                                                                  C, Shutdown Operations Significance Determination                Determination Process, should not be used to evaluate this finding and stated that NRRIDRA did not believe this performance deficiency affected operations during shutdown conditions. Lois James NRRlDRA referenced IMC 0609 ,, the RASP Handbook, and a review of past findings as the basis for this decision. Her email of 3/3/20 10 describes this argument and it is attached.
3/3/2010 Additional Additional meetings        meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, perpectives.
came to    to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance                                          Performance Assessment Assessment Branch, expressed              expressed concern over the whether    whether it was programmati programmatically  cally appropriate and consistent to use            use Appendix Appendix G            G for this finding considering considering that the finding occurred At-power.
On April April 30,    30, 2010,  2010, after considering all    all of  the perspectives, of the  perspectives, John Lubinski  Lubinski (acting DRS director) determined that it was consistent consistent with our              our process and practice practice to process to    to treat thisthis as as an At-Power finding. In other words,          words, we would not      not view this this asas aa finding finding warranting an Appendix C                    G risk assessment. It          would screen out It would              out per per IMC 0609 0609 Phase Phase 11 screening. To      To perform perform maintenance maintenance to          to correct correct the the leak, leak, the the licensee licensee shutdown shutdown and entered    entered reduced reduced inventory inventory operation.
operation. We    We did did not not identify identify performance performance deficiencies  deficiencies associated associated withwith the the licensees licensee's shutdown shutdown operations operations or  or maintenance maintenance risk managment.managment.
(Reference (Reference Lubinski      Lubinski email email 4/30/10, 4/30110, attached).
attached). Rani  Rani Franovich, Franovich,Chief  Chief of of Performance Performance Assessment, agreed        agreed withwith this decision decision via email via    email on      on 6/4/2016/4/2010. 0.
II have have reviewed reviewed this          this non-concurre non-concurrence  nce documentatio documentation      n in in detail.
detail. It    illustrates the It illustrates    the numerous numerous important important arguments arguments and  and counter-argu counter-arguments            ments that that the    staff discussed the staff  discussed and and highlights highlights several several areasareas for for potential potential SDPSDP guidance guidance clarification.
clarification. Because Because II believe believe that  that these    these arguments arguments were were thoughtfully thoughtfully considered considered in    in the the April April 3030 decision, decision, II do do not not propose propose reversing reversing thatthat decision.
decision.
The performance The    performance deficiency        deficiency was was not not viewed viewed to  to extend extend intointo the the licensees licensee's decisions decisions to  to shutdown shutdown and  and repair.
repair. To  To address address staff staff division division and    and concerns  concerns overover this, this, DIRS DIRS initiated initiated an an effort effort toto examine examine whether whether changes changes werewere needed needed in  in NRC NRC procedures procedures to  to ensure clarity, ensure        clarity, reliability,              and efficiency reliability, and    efficiency going going forward.
forward. DIRS DIRS initiated initiated an an ROP ROP feedback feedback formform to to track track thisthis effort.
effort.
(Reference (Reference Franovich      Franovich email          6/4/10) II believe, email 6/4/10)      believe, on on balance, balance, that that the the decisions decisions to  to treat treat this this finding finding as as an an At-Power At-Power finding finding and and to to conduct conduct aa review        review ofofour our guidance guidance are are inin the the interests interests of of ROP ROP reliability reliability andand clarity, clarity, which which areare inin the the the the public public interest.
interest.
This path This    path also    also provides provides forfor additional additional stakeholder stakeholder participation participation and    and communicati communication        should SDP on should      SDP guidance guidance revisions revisions occur.
occur.
D CONTINUED CONTINUED IN    IN SECTION SECTION DD tsSTGiI~
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                              '?:' ~    ~ij&#xa5;SPOJ~'~$*~~~cr=-rDDA~:TIT~~'Z-~;;,/,l"-11W@YA~51G"~                                                                        1';;Zb (;0 DAT NON-CONCURRING INDIVIDUAL (To be completed by documerl sponsor when process                                              process isis complete, complete, i.e.,
i.e., after after document document isis signed):
signed):
D      CONCURS CONCURS                                                                              c6
                                                                                                                                /WANTSWANTS NCP NCP FORM FORM PUBLIC PUBLIC o/      NON-CONCURS NON-CONCURS                                                                          D    WANTS WANTS NCP NCP FORM FORM NON-PUBLIC NON-PUBLIC D      WITHDRAWS W ITHDRAWS NON-CONCURRENCE NON-CONCURRENCE (i.e.,      (Le.,discontinues discontinuesprocess) process)
NRC  FORM757 NRCFORM        757 (3-2009)
(3-2009)                                        Use UseADAMS ADAMS Template TemplateNRC-006 NRC-D06                                                  PRINTEDON PRINTED  ONRECYCLED RECYCLEDPAPER PAPER
 
Lo        -LQA Franke, Mark Franke,    Mark From:
From:                              Nease, Rebecca Nease,    Rebecca Sent:
Sent:                              Friday, March Friday,  March 05, 05, 20102:34 2010 2:34 PM  PM To:                                Franke, Mark; Vargas, Franke,             Vargas, Alexandra


==Subject:==
==Subject:==
Nease, Rebecca Friday, March 05, 20102:34 PM Franke, Mark; Vargas, Alexandra FW: SDP Phase 3 Analysis Of St. Lucie Rep Seal Leak-Off Line Leak NRR's basis for not using App G. From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie


==Subject:==
==Subject:==
SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line Leak Rebecca, The Probabilistic Risk Assessment Operational Support Sranch (APOS) was requested by Engineering Branch 2 in the Division of Reactor Safety in Region II to perform a Phase 3 Significance Determinat i on Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) requ i red unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance def i ciency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld. APOS staff forwarded the Phase 3 SDP to Region II staff on February 24, 2010. During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place. Clearly, the performance deficiency caused a TS require unit shutdown, however, the performance deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant.
FW: SDP Phase FW:                      Analysis Of St.
Therefore, NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding. In addition, NRRlDRA believes that this performance deficiency does not affect the operations during shutdown conditions and that available guidance provides that IMC 0609, Appendix G, is applicable to finding that affect the operations during shutdown conditions.
Phase 3 Analysis                   Lucie Rep St. Lucie   RCP Seal Leak-Off Leak-Off Line Line Leak Leak NRRs basis NRR's  basis for notnot using using App G. G.
* IMC 0309 Appendix G , Shutdown Operations Significance Determination Process (IMC 0609, App G), states that: o For deficiencies occurring above the RHR entry conditions, the full power SDP tools should be used ... [section 2.1] o An initiating event at shutdown is defined as an event that causes a loss or interruption of the decay heat removal function.
From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM Sent:
[section 4.0]
To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie
* IMC 0609 Attachment 4 provides guidance that performance deficiencies during shutdown modes to be evaluated using Appendix G: o IF the finding affects: the safety of a reactor during refueling outages, forced outages, and maintenance outages starting, when the licensee has met the entry conditions for RHR and RHR cooling has been initiated, THEN STOP. Go to IMC 0609, Appendix G.
* The RASP Handbook provides a specific exception when repair time should not be included in the exposure time to deal with this type of finding: o If the plant is shutdown and the deficiency only affects an at-power condition, then repair time should not be included 1 Further. NRRlDRA performed a quick search of findings on the Dynamic Webs Page to identify findings that were found at-power and included risk insights from IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. No findings were identified that applied IMC 0609 Appendix G to an at-power finding. We could only locate items that used IMC 0609 Appendix G when the items were identified during shutdown.
In conclusion, while the PRA analysis completed that was forwarded to your staff on February 24 , 2010, is technically adequate in calculating the risk associated with reduced inventory, NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding. If you would like to discuss this further, please feel free to contact me. Lois James , Chief PRA Operational Support (APOB) Divis i on of R i sk Assessment (ORA) Office of Nuclear Reactor Regulation (NRR) 30 1-415-3306 lois. james@nrc.gov 2 
" Franke, Mark From: Sent: To: Cc:  


==Subject:==
==Subject:==
Attachments:
SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line                  Line Leak
Importance:
: Rebecca, The Probabilistic Risk Assessment Operational Support Sranch                      Branch (APOS)
Hey John, Franovich, Rani Friday, June 04, 2010 9:01 AM Lubinski, John Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff; Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca RE: St Lucie RCP seal weld SDP discussion Draft ROPFF for St Lucie High Good seeing you yesterday.
(APOB) was requested by Engineering Branch 2 in the Division of Reactor Safety in Region II to perform a Phase 3 Significance Determination Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) required unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance deficiency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld.                                  J-weld.
As I mentioned at the All Supervisors' Meeting, DIRS agrees with Region II's significance characterization of the St. Lucie finding involving the RCP lower cavity seal line J-weld failure. We also agree with the sentiments you expressed below and recognize the need to examine governing guidance.
APOB APOS    staff  forwarded      the  Phase    3  SDP      to  Region II staff on February 24, 2010.
We have initiated a feedback form to capture lessons learned and determine how and where that guidance can be clarified to ensure regional consistency/reliability.
During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place.
Paul forwarded the feedback form to Walt (see attached) for his review before I approve ... just wanted folks in HQ and RII to be aware. I'm sure you enjoyed Atlanta and RII; we l come back to HQ ... Rani From: Lubinski, John Sent: Friday, April 30, 2010 2:24 PM To: Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Cc: Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Check , Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca  
place. Clearly, the performance deficiency caused aa TS require unit shutdown, however, the performance deficiency, deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRR/DRA NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Significance Determination Process, should be used to evaluate this finding.
In addition, NRRlDRA NRR/DRA believes that this performance  performance deficiency does not          not affect the operations during shutdown conditions conditions and that available guidance provides that IMC 0609, Appendix G, is applicable to finding that affect the operations during shutdown conditions.      conditions.
* IMC IMC 0309 Appendix G,         G, Shutdown Operations Significance Determination    Determination Process (IMC    (IMC 0609, 0609, App App G), states that:
G), states    that:
oo For For deficiencies deficiencies occurring occurring aboveabove the  the RHR RHR entry entry conditions, thethe full full power power SDP SDP tools tools should should be  be used.
used ....[section
                                                    . [section 2.1]
2.1]
oo  An initiating An    initiating event event at  at shutdown shutdown is    is defined defined as  as an  event that an event  that causes causes aa loss loss or or interruption interruption of of the the decay decay heat heat removal removal function. [section [section 4.0]4.0]
* IMC    0609 Attachment IMC 0609        Attachment 44 provides provides guidance guidance that  that performance performance deficiencies deficiencies during during shutdown shutdown modes modes to be  evaluated      using  Appendix to be evaluated using Appendix G:              G:
oo IFIF the the finding finding affects:
affects: the the safety safety of  of aa reactor reactor during during refueling refueling outages, outages, forced forced outages, outages, and and maintenance maintenance outages outages starting,        when the starting, when        the licensee licensee has has met met the the entry entry conditions conditions for for RHR RHR and and RHR RHR cooling cooling has has been been initiated, initiated, THENTHEN STOP.
STOP. Go Go to to IMC IMC 0609, 0609, Appendix Appendix G. G.
          **    The The RASP RASP Handbook Handbook provides provides aa specific specific exception exception when when repair repair time time should should not not be be included included in in the the exposure exposure time  time toto deal  with this deal with      this type type ofof finding:
finding:
oo IfIf the the plant plant isis shutdown shutdown and   and the the deficiency deficiency only only affects affects an an at-power at-power condition, condition, then then repair repair time time should should notnot bebe included included 11
 
Further, NRRlDRA Further. NRR/DRA performed performed aa quick quick search search of    findings on of findings  on the  Dynamic Webs the Dynamic  Webs Page Page toto identify identify findings findings that that were found were    found at-power at-power andand included included risk risk insights insights from from IMC IMC 0609 0609 Appendix Appendix G,G, Shutdown Operations Significance Shutdown    Operations      Significance Determination Process.
Determination        Process. No  No findings findings were were identified identified that that applied applied IMC IMC 0609 0609 Appendix Appendix G  G toto an an at-power at-power finding.
finding.
We    could  only  locate  items We could only locate items that    that used used IMC IMC 0609 0609 Appendix Appendix G      when the C when  the items items were were identified identified during during shutdown.
shutdown.
In conclusion, In    conclusion, while while the  PRA analysis the PRA    analysis completed completed thatthat was was forwarded forwarded toto your your staff staff on on February February 24, 24, 2010, 2010, is is technically adequate technically    adequate in  in calculating calculating the the risk risk associated associated with with reduced reduced inventory, inventory, NRRlDRA NRR/DRA does  does not believe that not  believe  that IMC 0609 IMC    0609 Appendix G,        Shutdown Operations G, Shutdown      Operations Significance Significance Determination Determination Process, Process, should be should    be used used toto evaluate evaluate this finding.
this  finding.
IfIf you you would like like to to discuss this this further, further, please please feel feel free free to contact contact me.
me.
Lois James, Lois    James, Chief Chief PRA Operational Support (APOB)
Division of Risk Assessment (ORA)    (DRA)
Office of Nuclear Reactor Regulation (NRR) 301-41 5-3306 301-415-3306 lois. ja lois. mes(nrc. qov james@nrc.gov 22
 
rov&cnJCn LV
" Franke,
- Franke, Mark Mark From:
From:                         Franovich, Rani Franovich, Rani Sent:
Sent:                         Friday, June Friday, June 04, 04, 2010   9:01 AM 2010 9:01 To:
To:                           Lubinski, John Lubinski, John Cc:
Cc:                          Rogers, Walt; Rogers,   Walt; Vargas,    Alexandra; Zoulis, Vargas, Alexandra;                        James, Lois; Zoulis, Antonios; James,         Laur, Steven; Lois; Laur, Steven; Ashley, Ashley, MaryAnn; Circle, MaryAnn;            Jeff; Franke, Circle, Jeff;  Franke, Mark;    Kennedy, Kriss; Mark; Kennedy,   Kriss; Christensen,           Sykes, Marvin; Harold; Sykes, Christensen, Harold;            Marvin; Leonard; Munday, Wert, Leonard; Wert,                              Cheok, Michael; Joel; Cheok, Munday, Joel;                       Cunningham, Mark; Michael; Cunningham,     Mark; Galloway,    Melanie; Nease, Galloway, Melanie;     Nease, Rebecca Rebecca


==Subject:==
==Subject:==
St Lucie RCP seal weld SDP discussion My thanks to everyone for participating in yesterday's conference call to discuss your perspectives on SOP treatment for a potential St. Lucie RCP seal weld leak finding. After considering all views presented, and after additional discussion with Mark Franke, I believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment.
To perform maintenance to correct the leak, the licen'see shutdown and entered reduced inventory operation.
We did not identify performance deficiencies associated with licensee shutdown operations or maintenance risk management as they affected repairs. The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's quarterly report. In addition, our review of this finding clearly demonstrates that our SOP procedures and processes need to be examined.
As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. I will talk with NRRlOIRS about the next steps for such an examination.
1 Of Franke, Mark From: Sent: To: Cc:


==Subject:==
==Subject:==
Lubinski , John Friday, April 30, 2010 2:24 PM Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur , Steven; Ashley, MaryAnn; Circle, Jeff Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham , Mark; Galloway, Melanie; Nease, Rebecca St Lucie RCP seal weld SOP discussion My thanks to everyone for participating in yesterday's conference call to discuss your perspectives on SDP treatment for a potential St. Lucie Rep seal weld leak finding. After considering all views presented, and after additional discussion with Mark Franke, I believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment.
RE: St RE:  St Lucie Lucie RCP RCP seal seal weld weld SDP SDP discussion discussion Attachments:
To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation.
Attachments:                  Draft ROPFF Draft  ROPFF forfor St St Lucie Lucie Importance:
We did not identify performance deficiencies associated with licensee shutdown operations or maintenance risk management as they affected repairs. The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's quarterly report. In addition, our review of this finding clearly demonstrates that our SDP procedures and processes need to be examined.
Importance:                  High High Hey John, Hey  John, Good seeing Good    seeing you you yesterday. As II mentioned at      at the                      Meeting, DIRS Supervisors' Meeting, the All Supervisors                DIRS agrees            Region Ils agrees with Region      II's significance characterization significance    characterization of of the St.                    involving the RCP lower finding involving St. Lucie finding                            lower cavity seal seal line  J-weld failure.
As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. I will talk with NRRlDIRS about the next steps for such an examination.
line J-weld  failure . We also agree with the sentiments also                                you expressed below sentiments you                    below and and recognize the need  need to examine      governing guidance.
1 NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRC MD 10.158 (3-2009) NON-CONCURRENCE PROCESS TITLE OF DOCUMENT I ADAMS ACCESSION NO. St. Lucie Inspection Report 05000389/2010003 SECTION 0: CONTINUATION PAGE CONTINUATION OF SECTION D A D B D C NRC FORM 757 (3-2009) Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER}}
examine governing        guidance.
We have initiated aa feedback form form to capture                learned and lessons learned capture lessons                                    how and determine how and  and  where    that guidance guidance can be clarified to ensure              consistency/reliability. Paul ensure regional consistency/reliability.          Paul forwarded thethe feedback form to  to Walt (see (see attached) for his attached)        his review before II approve..,    just wanted folks approve ... just                          HQ and folks in HQ        RII to be aware.
and Rll        aware.
I'm sure you enjoyed Atlanta and RII; Im                                    RIl; welcome back to HQ... HQ ...                                                ,    I Rani                                                                                                        TC)r            L(S John From: Lubinski, John Friday, April 30, 2010 2:24 PM Sent: Friday, Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; To: Franovich,                                                                            Lois; Laur, Steven; Ashley, MaryAnn; MaryAnn; Circle, Jeff Cc: Franke, Mark; Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok,        Check, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca
 
==Subject:==
St Lucie RCP seal weld SDP discussion yesterday's conference call to discuss your perspectives on SOP My thanks to everyone for participating in yesterdays                                                                        SDP treatment for a potential St. Lucie RCP seal weld leak finding.
After considering all views presented, and after additional discussion with Mark Franke, II believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licen's ee shutdown and entered reduced inventory operation. We did not identify performance deficiencies licensee associated with licensee shutdown operations or maintenance risk management as they affected repairs.
The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's residents quarterly report.
In addition, our review of this finding clearly demonstrates that our SOP          SDP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's         licensees actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. II will talk with NRRlOIRS  NRRJDIRS about the next steps for such an examination.
11
 
Of. Franke, Mark Franke,    Mark From:
From:                          Lubinski, Lubinski, John John Sent:
Sent:                          Friday, Friday, April April 30,  2010 2:24 30, 2010    2:24 PM PM To:
To:                            Franovich,  Rani; Rogers, Walt; Franovich, Rani;              Walt; Vargas,  Alexandra; Zoulis, Vargas, Alexandra;    Zoulis, Antonios; James, Lois; Antonios; James,  Lois; Laur, Laur, Steven; Steven; Ashley,                Circle, Jeff MaryAnn; Circle, Ashley, MaryAnn;              Jeff Cc:
Cc:                            Franke,          Kennedy, Kriss; Mark; Kennedy, Franke, Mark;                Kriss; Christensen, Christensen, Harold;            Marvin; Wert, Sykes, Marvin; Harold; Sykes,                  Leonard; Munday, Wert, Leonard;    Munday, Joel; Check, Joel;          Michael; Cunningham, Cheok, Michael;                      Mark; Galloway, Cunningham , Mark;                  Melanie; Nease, Galloway, Melanie;    Nease, Rebecca Rebecca
 
==Subject:==
 
==Subject:==
St Lucie St Lucie RCP    seal weld RCP seal          SOP discussion weld SDP    discussion My thanks My  thanks to    everyone for to everyone  for participating in    yesterday's conference in yesterdays    conference call        discuss your to discuss call to                perspectives on your perspectives      on SDP SDP treatment for aa potential potential St.        Rep seal weld leak St. Lucie RCP                    leak finding.
After considering After                    views presented, considering all views    presented, and after                    discussion with after additional discussion                  Franke, II believe Mark Franke, with Mark                            is consistent believe itit is our process with our  process to move move forward to  to treat treat this      an At-Power finding. In as an this as                                other words, we In other              would not we would  not viewview this as aa finding warranting an as                          an Appendix Appendix G  G risk risk  assessment.      To To  perform  maintenance maintenance to  to correct  the leak, the the leak, licensee shutdown licensee    shutdown andand entered                inventory operation.
entered reduced inventory          operation. We We did did not            performance deficiencies identify performance not identify                deficiencies associated withwith licensee shutdown operations              maintenance risk management as they affected repairs.
operations or maintenance                                                      repairs.
next steps The next                    action will be for Mark steps for this action                  Mark Franke to  to provide            input to DRP provide written input              Branch 33 for inclusion DRP Branch            inclusion inin next residents the next  resident's quarterly quarterly report.
report.
demonstrates that our SDP procedures and processes need to be In addition, our review of this finding clearly demonstrates examined. As our guidance is currently written, aa number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on  on whether itit was appropriate to include risk associated                      licensee's actions to fix the associated with the licensees leak. In leak. In the interests of program reliability, we believe that NRR should      should examine whether changes are        are needed needed to clarify or change our policy going                                      NRRJDIRS about the next steps for such an going forward. II will talk with NRRlDIRS examination.
1
 
NRC FORM 757 NRC            757                                                    U.S. NUCLEAR REGULATORY COMMISSION COMMISSION NRC MD NRC      10.158 MD 10.158 (3-2009)
(3-2009)
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT                                                                     I ADAMS ACCESSION NO. NO.
St. Lucie Inspection Report 05000389/2010003 SECTION 0:    D: CONTINUATION CONTINUATION PAGE CONTINUATION OF      OF SECTION D   A D   B B
D   C NRC FORM NRC  FORM 757 757 (3-2009)
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Revision as of 15:31, 13 November 2019

NRC Integrated Inspection Report 2010003 - Non-Concurrence (Public)
ML102100007
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 06/28/2010
From: Mark Franke
NRC/RGN-II/DRS/EB3
To:
References
IR-01-003
Download: ML102100007 (8)
v • d • e


Text

NRC FORM NRC FORM 757 757 u.s. NUCLEAR REGULATORY U.S. NUCLEAR REGULATORY COMMISSION COMMISSION NRC MD NRC MD 10.158 10158 (3-2009)

(3*2009)

NON-CONCURRENCE PROCESS SECTION A SECTION A - TO

- TO BEBE COMPLETED COMPLETED BY BY NON-CONCURRING INDIVIDUAL NON-CONCURRING INDIVIDUAL TITLE OF TITLE OF DOCUMENT DOCUMENT ADAMS ADAMS ACCESSION NO. NO.

Inspection Report St. Lucie Inspection 05000389/2010003 Reøort 05000389/2010003 DOCUMENT SPONSOR DOCUMENT SPONSOR SPONSOR SPONSOR PHONEPHONE NO.

NO.

Mark Franke Mark Franke 404-997-4436 404-997-4436 NAME OF NAME OF NON-CONCURRING INDIVIDUAL NON-CONCURRING INDIVIDUAL PHONE PHONE NO. NO.

Walt Rogers 404-997-4619 D DOCUMENT AUTHOR DOCUMENT AUTHOR D DOCUMENT CONTRIBUTOR DOCUMENT D DOCUMENT REVIEWER DOCUMENT REVIEWER ~ ON ON CONCURRENCE TITLE TITLE ORGANIZATION Senior Reactor Analyst DRS/EB2 IDRSlEB2 REASONS FOR NON-CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance. The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivtiesactiivties..

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DOCUMENT SPONSOR SPONSOR AND AND COPY eOPY TO TO YOUR YOUR IMMEDIATE IMMEDIATE SUPER

.. L SUPERVISOR ISOR ANDAND Ji r .'

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DIFFERING DIFFERING VIEWS VIEWS PROGRAM PROGRAM MANAGER MANAGER NRC NRC FORM FORM 757 757 (3-2009)

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NRC FORM 757 NRC NUCLEAR REGULATORY COMMISSION U.S. NUCLEAR 10.158 NRC MD 10.158 (3-2009)

NON-CONCURRENCE PROCESS TITLE OF DOCUMENT IADAMS ACCESSION NO.

05000389/2010003 St. Lucie Inspection Report 0500038912010003 SECTION B - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S

- INDMDUALS SUPERViSOR SUPERVISOR (THIS SECTION SHOULD ONLY BE BE COMPLETED IF DIFFERENT THAN DOCUMENT SPONSOR.)

IF SUPERVISOR IS DIFFERENT NAME Rebecca L. Nease TITLE PHONE NO.

Cbief, Engineering Brancb

Chief, ORGANIZATION ORGANIZATION Branch 2 I 404-997-4530 Division of Reactor Safety. Safety, Region IID COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER D II HAVE HAVE NO COMMENTS

!ill II HAVE THE FOLLOWING COMMENTS I have bave reviewed the tbe attacbed attached documentation, and it appears that tbat all parties have faitb, to consider all views bave acted in good faith, witb repsect to the with tbe subject of tbis this non-concurrence. At issue is whether wbetber is is appropriate to use the shutdown operations tbe sbutdown significnce determination process (SDP) or the tbe at-power SDP for tbethe described performance deficiency. While a conclusion reacbed tbat was reached that sbutdown shutdown risk was not to be considered, it appears that this was not a consensus view among the tbat tbis tbe staff in NRR and Region II. D. In addition, it appears tbat have supported eitber tbe guidance could bave that the either view, depending on which wbicb part of tbe the guidance was referenced. Tbis This ambiguity does not speak well for our principals of good regulation, especially tbe the principal of clarity.

Having reviewed tbe the documents attacbed attached berein, each view, eitber herein, and read eacb either metbodology (shutdown risk or at-power risk) methodology (sbutdown appears to meet at least some parts oftbe shutdown risk to conclude a bigber of the guidance. However, in using sbutdown higher risk level, we would havebave hadbad tbe the opportunity (witbin (within tbe the guidance) to send a strong message to tbe the licensee tbat that repeatedly entering a risk-signficant plant configuration to fIX fix tbe the same or similar degraded condition is not in tbe the interest of safety. I believe tbe the confusing guidance bears revision to provide clarity to tbe the process and to permit sucb such latitide in egregious cases, sucb this such as tbis one.

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SIGNAT E DATE SIGNAfLr1l/l v

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, NRC FORM NRC FORM 757 NRC MD10.158 NRC MD 10158 (3-2009) 757 U.S.

U.S. NUCLEAR NUCLEAR REGULATORY REGULATORY COMMISSION COMMISSION (3-2009)

NON-CONCURRENCE PROCESS NON~ONCURRENCEPROCESS TITLE OF TITLE OF DOCUMENT DOCUMENT IADAMS ADAMS ACCESSION ACCESSION NO. NO.

St Lucie 8t Lucie Inspection Inspection Report Report 05000389/2010003 05000389/2010003

~I-------------------

SECTION CC - TO SECTION - BE COMPLETED TO BE COMPLETED BY DOCUMENT SPONSOR BY DOCUMENT SPONSOR NAME

NAME Mark Franke Mark Franke TITLE TITLE PHONE PHONE NO.NO.

Branch Chief Branch Chief 404-997-4436 ORGANIZATION I 404-997-4436 ORGANIZATION DRS/EB3 DRSlEB3

-ACTIONS - -TAKEN ACTIONS TAKEN

- -TO -ADDRESS

-

TO ADDRESS NON-CONCURRENCE (This NON-CONCURRENCE (This section section should should bebe revised revised,, as necessary, to as necessary, to reflect reflect the the final final outcome outcome ofof the the non-concurrence process, non-concurrence process, including including aa complete complete discussion discussion ofof how individual concerns how individual concerns were were addressed.)

addressed.)

The issue at The at the heart of this this non-concurrence non-concurrence is whether it it is appropriate to assess shutdown shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed failed seal line finding.

II believe believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and and NRR DIRS and DRA.

On March On March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix G, C, Shutdown Operations Significance Determination Determination Process, should not be used to evaluate this finding and stated that NRRIDRA did not believe this performance deficiency affected operations during shutdown conditions. Lois James NRRlDRA referenced IMC 0609 ,, the RASP Handbook, and a review of past findings as the basis for this decision. Her email of 3/3/20 10 describes this argument and it is attached.

3/3/2010 Additional Additional meetings meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, perpectives.

came to to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance Performance Assessment Assessment Branch, expressed expressed concern over the whether whether it was programmati programmatically cally appropriate and consistent to use use Appendix Appendix G G for this finding considering considering that the finding occurred At-power.

On April April 30, 30, 2010, 2010, after considering all all of the perspectives, of the perspectives, John Lubinski Lubinski (acting DRS director) determined that it was consistent consistent with our our process and practice practice to process to to treat thisthis as as an At-Power finding. In other words, words, we would not not view this this asas aa finding finding warranting an Appendix C G risk assessment. It would screen out It would out per per IMC 0609 0609 Phase Phase 11 screening. To To perform perform maintenance maintenance to to correct correct the the leak, leak, the the licensee licensee shutdown shutdown and entered entered reduced reduced inventory inventory operation.

operation. We We did did not not identify identify performance performance deficiencies deficiencies associated associated withwith the the licensees licensee's shutdown shutdown operations operations or or maintenance maintenance risk managment.managment.

(Reference (Reference Lubinski Lubinski email email 4/30/10, 4/30110, attached).

attached). Rani Rani Franovich, Franovich,Chief Chief of of Performance Performance Assessment, agreed agreed withwith this decision decision via email via email on on 6/4/2016/4/2010. 0.

II have have reviewed reviewed this this non-concurre non-concurrence nce documentatio documentation n in in detail.

detail. It illustrates the It illustrates the numerous numerous important important arguments arguments and and counter-argu counter-arguments ments that that the staff discussed the staff discussed and and highlights highlights several several areasareas for for potential potential SDPSDP guidance guidance clarification.

clarification. Because Because II believe believe that that these these arguments arguments were were thoughtfully thoughtfully considered considered in in the the April April 3030 decision, decision, II do do not not propose propose reversing reversing thatthat decision.

decision.

The performance The performance deficiency deficiency was was not not viewed viewed to to extend extend intointo the the licensees licensee's decisions decisions to to shutdown shutdown and and repair.

repair. To To address address staff staff division division and and concerns concerns overover this, this, DIRS DIRS initiated initiated an an effort effort toto examine examine whether whether changes changes werewere needed needed in in NRC NRC procedures procedures to to ensure clarity, ensure clarity, reliability, and efficiency reliability, and efficiency going going forward.

forward. DIRS DIRS initiated initiated an an ROP ROP feedback feedback formform to to track track thisthis effort.

effort.

(Reference (Reference Franovich Franovich email 6/4/10) II believe, email 6/4/10) believe, on on balance, balance, that that the the decisions decisions to to treat treat this this finding finding as as an an At-Power At-Power finding finding and and to to conduct conduct aa review review ofofour our guidance guidance are are inin the the interests interests of of ROP ROP reliability reliability andand clarity, clarity, which which areare inin the the the the public public interest.

interest.

This path This path also also provides provides forfor additional additional stakeholder stakeholder participation participation and and communicati communication should SDP on should SDP guidance guidance revisions revisions occur.

occur.

D CONTINUED CONTINUED IN IN SECTION SECTION DD tsSTGiI~

GN~.-~  : : : : :. .- --m{~

'?:' ~ ~ij¥SPOJ~'~$*~~~cr=-rDDA~:TIT~~'Z-~;;,/,l"-11W@YA~51G"~ 1';;Zb (;0 DAT NON-CONCURRING INDIVIDUAL (To be completed by documerl sponsor when process process isis complete, complete, i.e.,

i.e., after after document document isis signed):

signed):

D CONCURS CONCURS c6

/WANTSWANTS NCP NCP FORM FORM PUBLIC PUBLIC o/ NON-CONCURS NON-CONCURS D WANTS WANTS NCP NCP FORM FORM NON-PUBLIC NON-PUBLIC D WITHDRAWS W ITHDRAWS NON-CONCURRENCE NON-CONCURRENCE (i.e., (Le.,discontinues discontinuesprocess) process)

NRC FORM757 NRCFORM 757 (3-2009)

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Lo -LQA Franke, Mark Franke, Mark From:

From: Nease, Rebecca Nease, Rebecca Sent:

Sent: Friday, March Friday, March 05, 05, 20102:34 2010 2:34 PM PM To: Franke, Mark; Vargas, Franke, Vargas, Alexandra

Subject:

Subject:

FW: SDP Phase FW: Analysis Of St.

Phase 3 Analysis Lucie Rep St. Lucie RCP Seal Leak-Off Leak-Off Line Line Leak Leak NRRs basis NRR's basis for notnot using using App G. G.

From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM Sent:

To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie

Subject:

SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line Line Leak

Rebecca, The Probabilistic Risk Assessment Operational Support Sranch Branch (APOS)

(APOB) was requested by Engineering Branch 2 in the Division of Reactor Safety in Region II to perform a Phase 3 Significance Determination Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) required unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance deficiency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld. J-weld.

APOB APOS staff forwarded the Phase 3 SDP to Region II staff on February 24, 2010.

During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place.

place. Clearly, the performance deficiency caused aa TS require unit shutdown, however, the performance deficiency, deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRR/DRA NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Significance Determination Process, should be used to evaluate this finding.

In addition, NRRlDRA NRR/DRA believes that this performance performance deficiency does not not affect the operations during shutdown conditions conditions and that available guidance provides that IMC 0609, Appendix G, is applicable to finding that affect the operations during shutdown conditions. conditions.

  • IMC IMC 0309 Appendix G, G, Shutdown Operations Significance Determination Determination Process (IMC (IMC 0609, 0609, App App G), states that:

G), states that:

oo For For deficiencies deficiencies occurring occurring aboveabove the the RHR RHR entry entry conditions, thethe full full power power SDP SDP tools tools should should be be used.

used ....[section

. [section 2.1]

2.1]

oo An initiating An initiating event event at at shutdown shutdown is is defined defined as as an event that an event that causes causes aa loss loss or or interruption interruption of of the the decay decay heat heat removal removal function. [section [section 4.0]4.0]

  • IMC 0609 Attachment IMC 0609 Attachment 44 provides provides guidance guidance that that performance performance deficiencies deficiencies during during shutdown shutdown modes modes to be evaluated using Appendix to be evaluated using Appendix G: G:

oo IFIF the the finding finding affects:

affects: the the safety safety of of aa reactor reactor during during refueling refueling outages, outages, forced forced outages, outages, and and maintenance maintenance outages outages starting, when the starting, when the licensee licensee has has met met the the entry entry conditions conditions for for RHR RHR and and RHR RHR cooling cooling has has been been initiated, initiated, THENTHEN STOP.

STOP. Go Go to to IMC IMC 0609, 0609, Appendix Appendix G. G.

    • The The RASP RASP Handbook Handbook provides provides aa specific specific exception exception when when repair repair time time should should not not be be included included in in the the exposure exposure time time toto deal with this deal with this type type ofof finding:

finding:

oo IfIf the the plant plant isis shutdown shutdown and and the the deficiency deficiency only only affects affects an an at-power at-power condition, condition, then then repair repair time time should should notnot bebe included included 11

Further, NRRlDRA Further. NRR/DRA performed performed aa quick quick search search of findings on of findings on the Dynamic Webs the Dynamic Webs Page Page toto identify identify findings findings that that were found were found at-power at-power andand included included risk risk insights insights from from IMC IMC 0609 0609 Appendix Appendix G,G, Shutdown Operations Significance Shutdown Operations Significance Determination Process.

Determination Process. No No findings findings were were identified identified that that applied applied IMC IMC 0609 0609 Appendix Appendix G G toto an an at-power at-power finding.

finding.

We could only locate items We could only locate items that that used used IMC IMC 0609 0609 Appendix Appendix G when the C when the items items were were identified identified during during shutdown.

shutdown.

In conclusion, In conclusion, while while the PRA analysis the PRA analysis completed completed thatthat was was forwarded forwarded toto your your staff staff on on February February 24, 24, 2010, 2010, is is technically adequate technically adequate in in calculating calculating the the risk risk associated associated with with reduced reduced inventory, inventory, NRRlDRA NRR/DRA does does not believe that not believe that IMC 0609 IMC 0609 Appendix G, Shutdown Operations G, Shutdown Operations Significance Significance Determination Determination Process, Process, should be should be used used toto evaluate evaluate this finding.

this finding.

IfIf you you would like like to to discuss this this further, further, please please feel feel free free to contact contact me.

me.

Lois James, Lois James, Chief Chief PRA Operational Support (APOB)

Division of Risk Assessment (ORA) (DRA)

Office of Nuclear Reactor Regulation (NRR) 301-41 5-3306 301-415-3306 lois. ja lois. mes(nrc. qov james@nrc.gov 22

rov&cnJCn LV

" Franke,

- Franke, Mark Mark From:

From: Franovich, Rani Franovich, Rani Sent:

Sent: Friday, June Friday, June 04, 04, 2010 9:01 AM 2010 9:01 To:

To: Lubinski, John Lubinski, John Cc:

Cc: Rogers, Walt; Rogers, Walt; Vargas, Alexandra; Zoulis, Vargas, Alexandra; James, Lois; Zoulis, Antonios; James, Laur, Steven; Lois; Laur, Steven; Ashley, Ashley, MaryAnn; Circle, MaryAnn; Jeff; Franke, Circle, Jeff; Franke, Mark; Kennedy, Kriss; Mark; Kennedy, Kriss; Christensen, Sykes, Marvin; Harold; Sykes, Christensen, Harold; Marvin; Leonard; Munday, Wert, Leonard; Wert, Cheok, Michael; Joel; Cheok, Munday, Joel; Cunningham, Mark; Michael; Cunningham, Mark; Galloway, Melanie; Nease, Galloway, Melanie; Nease, Rebecca Rebecca

Subject:

Subject:

RE: St RE: St Lucie Lucie RCP RCP seal seal weld weld SDP SDP discussion discussion Attachments:

Attachments: Draft ROPFF Draft ROPFF forfor St St Lucie Lucie Importance:

Importance: High High Hey John, Hey John, Good seeing Good seeing you you yesterday. As II mentioned at at the Meeting, DIRS Supervisors' Meeting, the All Supervisors DIRS agrees Region Ils agrees with Region II's significance characterization significance characterization of of the St. involving the RCP lower finding involving St. Lucie finding lower cavity seal seal line J-weld failure.

line J-weld failure . We also agree with the sentiments also you expressed below sentiments you below and and recognize the need need to examine governing guidance.

examine governing guidance.

We have initiated aa feedback form form to capture learned and lessons learned capture lessons how and determine how and and where that guidance guidance can be clarified to ensure consistency/reliability. Paul ensure regional consistency/reliability. Paul forwarded thethe feedback form to to Walt (see (see attached) for his attached) his review before II approve.., just wanted folks approve ... just HQ and folks in HQ RII to be aware.

and Rll aware.

I'm sure you enjoyed Atlanta and RII; Im RIl; welcome back to HQ... HQ ... , I Rani TC)r L(S John From: Lubinski, John Friday, April 30, 2010 2:24 PM Sent: Friday, Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; To: Franovich, Lois; Laur, Steven; Ashley, MaryAnn; MaryAnn; Circle, Jeff Cc: Franke, Mark; Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Check, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca

Subject:

St Lucie RCP seal weld SDP discussion yesterday's conference call to discuss your perspectives on SOP My thanks to everyone for participating in yesterdays SDP treatment for a potential St. Lucie RCP seal weld leak finding.

After considering all views presented, and after additional discussion with Mark Franke, II believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licen's ee shutdown and entered reduced inventory operation. We did not identify performance deficiencies licensee associated with licensee shutdown operations or maintenance risk management as they affected repairs.

The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's residents quarterly report.

In addition, our review of this finding clearly demonstrates that our SOP SDP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's licensees actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. II will talk with NRRlOIRS NRRJDIRS about the next steps for such an examination.

11

Of. Franke, Mark Franke, Mark From:

From: Lubinski, Lubinski, John John Sent:

Sent: Friday, Friday, April April 30, 2010 2:24 30, 2010 2:24 PM PM To:

To: Franovich, Rani; Rogers, Walt; Franovich, Rani; Walt; Vargas, Alexandra; Zoulis, Vargas, Alexandra; Zoulis, Antonios; James, Lois; Antonios; James, Lois; Laur, Laur, Steven; Steven; Ashley, Circle, Jeff MaryAnn; Circle, Ashley, MaryAnn; Jeff Cc:

Cc: Franke, Kennedy, Kriss; Mark; Kennedy, Franke, Mark; Kriss; Christensen, Christensen, Harold; Marvin; Wert, Sykes, Marvin; Harold; Sykes, Leonard; Munday, Wert, Leonard; Munday, Joel; Check, Joel; Michael; Cunningham, Cheok, Michael; Mark; Galloway, Cunningham , Mark; Melanie; Nease, Galloway, Melanie; Nease, Rebecca Rebecca

Subject:

Subject:

St Lucie St Lucie RCP seal weld RCP seal SOP discussion weld SDP discussion My thanks My thanks to everyone for to everyone for participating in yesterday's conference in yesterdays conference call discuss your to discuss call to perspectives on your perspectives on SDP SDP treatment for aa potential potential St. Rep seal weld leak St. Lucie RCP leak finding.

After considering After views presented, considering all views presented, and after discussion with after additional discussion Franke, II believe Mark Franke, with Mark is consistent believe itit is our process with our process to move move forward to to treat treat this an At-Power finding. In as an this as other words, we In other would not we would not viewview this as aa finding warranting an as an Appendix Appendix G G risk risk assessment. To To perform maintenance maintenance to to correct the leak, the the leak, licensee shutdown licensee shutdown andand entered inventory operation.

entered reduced inventory operation. We We did did not performance deficiencies identify performance not identify deficiencies associated withwith licensee shutdown operations maintenance risk management as they affected repairs.

operations or maintenance repairs.

next steps The next action will be for Mark steps for this action Mark Franke to to provide input to DRP provide written input Branch 33 for inclusion DRP Branch inclusion inin next residents the next resident's quarterly quarterly report.

report.

demonstrates that our SDP procedures and processes need to be In addition, our review of this finding clearly demonstrates examined. As our guidance is currently written, aa number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on on whether itit was appropriate to include risk associated licensee's actions to fix the associated with the licensees leak. In leak. In the interests of program reliability, we believe that NRR should should examine whether changes are are needed needed to clarify or change our policy going NRRJDIRS about the next steps for such an going forward. II will talk with NRRlDIRS examination.

1

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