ML20350B584

NRC-2018-000096 (Formerly FOIA/PA-2018-0003) - Resp 9 - Interim

ML20350B584
Person / Time
Issue date:	05/04/2020
From:	NRC/OCIO
To:	Kolar J Government Accountability Project
Shared Package
ML20350B580	List: ML20350B581 ML20350B582 ML20350B583 ML20350B584 ML20350B588
References
FOIA, FOIA/PA-2018-0003, NRC-2018-000096
Download: ML20350B584 (600)

Text

NRC FORM 464 Part I (OIG) U.S. NUCLEAR REGULATORY COMMISSION NRC RESPONSE NUMBER

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(09-2018) 2018-000096 9 J>l'IIEGt1{

! i RESPONSE TO FREEDOM OF I 11 I INFORMATION ACT (FOIA) REQUEST RESPONSE e;..,..,,+ ~

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o' TYPE INTERIM FINAL REQUESTER: DATE:

Jack Kolar, Government Accountability Project I I 05/04/2020 I

DESCRIPTION OF REQUESTED RECORDS:

Records corresponding to item 90, as further explained in the Comment Section, below.

PART I. -- INFORMATION RELEASED The NRC has made some, or all, of the requested records publicly available through one or more of the following means:

(1) https://www.nrc.gov; (2) public ADAMS, https://www.nrc.gov/reading-rm/adams.html; (3) microfiche available in the NRC Public Document Room; or FOIA Online, https://foiaonline.regulations.gov/foia/action/public/home.

Agency records subject to the request are enclosed.

Records subject to the request that contain information originated by or of interest to another Federal agency have been referred to that agency (See Part I.D -- Comments) for a disclosure determination and direct response to you.

We are continuing to process your request.

See Part I.D -- Comments.

PART I.A -- FEES Since the minimum fee threshold was not You will be billed by NRC for the amount indicated. met, you will not be charged fees.

AMOUNT You will receive a refund for the amount indicated. Due to our delayed response, you will not be charged search and/or duplication fees that 11 11 Fees waived.

would otherwise be applicable to your request.

PART I.B -- INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE We did not locate any agency records responsive to your request. Note: Agencies may treat three discrete categories of law enforcement and national security records as not subject to the FOIA ("exclusions"). See 5 U.S.C. 552(c). This is a standard notification given to all requesters; it should not be taken to mean that any excluded records do, or do not, exist.

We have withheld certain information pursuant to the FOIA exemptions described, and for the reasons stated, in Part II.

Because this is an interim response to your request, you may not appeal at this time. We will notify you of your right to appeal any of the responses we have issued in response to your request when we issue our final determination.

You may appeal this final determination within 90 calendar days of the date of this response. If you submit an appeal by mail, address it to the FOIA Officer, at U.S. Nuclear Regulatory Commission, Mail Stop T-2 F43, Washington, D.C. 20555-0001. You may submit an appeal by e-mail to FOIA.resource@nrc.gov. You may fax an appeal to (301) 415-5130. Or you may submit an appeal through FOIA Online, https://foiaonline.regulations.gov/foia/action/public/home. Please be sure to include on your submission that it is a FOIA Appeal.

PART I.C -- REFERENCES AND POINTS OF CONTACT You have the right to seek assistance from the NRC's FOIA Public Liaison by submitting your inquiry at https://www.nrc.gov/reading-rm/foia/contact-foia.html, or by calling the FOIA Public Liaison at (301) 415-1276.

If we have denied your request, you have the right to seek dispute resolution services from the NRC's Public Liaison or the Office of Government Information Services (OGIS). To seek dispute resolution services from OGIS, you may e-mail OGIS at ogis@nara.gov, send a fax to (202) 741-5789, or send a letter to: Office of Government Information Services, National Archives and Records Administration, 8601 Adelphi Road, College Park, MD 20740-6001. For additional information about OGIS, please visit the OGIS website at https://www.archives.gov/ogis.

NRC FORM 464 Part I (OIG) U.S. NUCLEAR REGULATORY COMMISSION NRC RESPONSE NUMBER

.l¥0*~.

(09-2018) 2018-000096 9 J>l'IIEGt1{

! i RESPONSE TO FREEDOM OF I 11 I INFORMATION ACT (FOIA) REQUEST RESPONSE e;..,..,,+ ~

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o' TYPE INTERIM FINAL PART I.D -- COMMENTS Item 90 asks for records pertaining to OIG allegation A13-07209, Special Project: NRC Regulatory Oversight. Your request notes that some of these records may have been assembled under FOIA/PA-2014-0336 and FOIA/PA-2015-0258. At the time these requests were processed, the project was open. As such, any responsive records were denied in their entirety on the basis of FOIA exemption 7(A). As the project is now closed, we have re-reviewed the records. Please note that the OIG has referred to the FOIA Officer for her determination records that originated with NRC program offices, which the OIG had compiled during this project. These program office records will be addressed by the FOIA Officer in interim response

1. 10.

Your continued patience is appreciated.

Signature - Assistant Inspector General for Investigations or Designee Rocco J. Pierri Digitally signed by Rocco J. Pierri Date: 2020.05.04 11:01:14 -04'00'

NRC FORM 464 Part II (OIG) U.S. NUCLEAR REGULATORY COMMISSION NRC (09-2018)

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RESPONSE TO FREEDOM OF

• 1 2018-000096#9 DATE:

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PART II.A -- APPLICABLE EXEMPTIONS Records subject to the request are being withheld in their entirety or in part under the FOIA exemption(s) as indicated below (5 U.S.C. 552(b)).

Exemption 1: The withheld information is properly classified pursuant to an Executive Order protecting national security information.

Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRC.

Exemption 3: The withheld information is specifically exempted from public disclosure by the statute indicated.

Sections 141-145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42 U.S.C. 2161-2165).

Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

41 U.S.C. 4702(b), which prohibits the disclosure of contractor proposals, except when incorporated into the contract between the agency and the submitter of the proposal.

Other:

Exemption 4: The withheld information is a trade secret or confidential commercial or financial information that is being withheld for the reason(s) indicated.

The information is considered to be proprietary because it concerns a licensee's or applicant's physical protection or material control and accounting program for special nuclear material pursuant to 10 CFR 2.390(d)(1).

The information is considered to be another type of confidential business (proprietary) information.

The information was submitted by a foreign source and received in confidence pursuant to 10 CFR 2.390(d)(2).

Exemption 5: The withheld information consists of interagency or intraagency records that are normally privileged in civil litigation.

Deliberative process privilege.

Attorney work product privilege.

Attorney-client privilege.

Exemption 6: The withheld information from a personnel, medical, or similar file, is exempted from public disclosure because its disclosure would result in a clearly unwarranted invasion of personal privacy.

Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated.

(A) Disclosure could reasonably be expected to interfere with an open enforcement proceeding.

(C) Disclosure could reasonably be expected to constitute an unwarranted invasion of personal privacy.

(D) The information consists of names and other information the disclosure of which could reasonably be expected to reveal identities of confidential sources.

(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be expected to risk circumvention of the law.

(F) Disclosure could reasonably be expected to endanger the life or physical safety of an individual.

. Other PART II.B -- DENYING OFFICIAL In accordance with 10 CFR 9.25(g)(1) of the U.S. Nuclear Regulatory Commission regulations, the official listed below has made the determination to withhold certain information, described below, responsive to your request.

DENYING OFFICIAL TITLE/OFFICE RECORDS DENIED APPELLATE OFFICIAL Assistant Inspector General for law enforcement, proprietary, and Rocco Pierri personally identifiable information; attorney- Inspector General Investigations client communications I

I I I NRC Form 464 Part II (OIG) (09-2018) Page 1 of 1

OFFICIAL USE ONLY Investigation Record Case Opened by: l(b)(?)(C) I 04/01/2013 Ca,~e

Title:

• Special Project: NRC Regulatory Case Number: C 13 027 Oversight Allegation Special Project: NRC Regulatory Allegation A 13 07209

Title:

• Oversight Number:

Titfe:*

Case Type: Proactive Initiative Allegation Referred to OIG Investigation Disposition:

Program NRC - Entire Date: 04/01/2013 Office:*

Referral OIG Memo Plant:

Method:*

Fiscal 201 3 Inv. Disposition Closed to File Year:*

Date 04/01 /2013 Closed Date: 07/11/2017 Allegation Received :*

Date of Status: Closed Permanent -

Alleged 08/02/2017; Offense: Referred to OIG Investigation

- 04/01/2013; Open Related A14-07527 Joint:

Allegations: l<b)(?J(El I Ai3-7185 A13-7192 A13-7193 A13-7194 A13-7301 A 14 07535 A 15 07591 A15 07602 i(b )(7)(E) i A 16-07901 ......,.....,.......,.... ..,........,~--,

A 16-07940,!(b)(?)(E) 1,!(b)(7)(E)

Allegation Info Alleger Information r b)(?)(E)

Anonymo No usr Name: Employer Home Address : Work OFFICIAL USE ONLY

OFFICIAL USE ONLY Address:

Home Phone: ,Work Phone:

E-mail: Source:* OIG Project Subject of Allegation:*

OIG special project: Self Initiated Allegation Facts:*

OIG special project to strengthen NRC's efforts to protect public health and safety and the environment by proactively monitoring agency technical and regulatory processes, nuclear industry trends, trade press, as well as other sources to identify potential problematic areas in NRC regulatory oversight of licensee.

This special project is a continuation of a previous project, OIG Project case number 10-12.

Attachments:

Related Cases:

Agent Recommendation:

Management Review of Allegation

~~~ .. ement Comments:*

(b)(?)(C) his is assigned to you for review of potential regulatory technical issues.

Follow-Up

• Yes O No Follow-Up 12/30/2016 Required:* Date:

Current Follow-Up Date:

Investigation Info (b)(?)(E)

OFFICIAL USE ONLY

OFFICIAL USE ONLY Planned Case Closure Date:* 09/30/2014 AssignmentSi Team: AIGI Case Agent: ... l(b-l(7_l(C_l _ ____.INRC Other Investigators: ._l (b.... c )_ ____,VNRC l(7_)(_

Case A ent History (b)(7)(C) assigned """'!(b"""'

)(7"""

)(C"'"

) ----,!NRC on 04/16/2013 Inv Plan1 Statutes & Regulations:

Initial lnvestiaative Steos :

(b)(7)(E)

OFFICIAL USE ONLY

OFFICIAL USE ONLY (b)(7)(E)

Level 1 Approval:

Level 2 Approv:il: Approved Joseph A. McMillan 12104/2014 09:39 AM Additional Investigative Steps :

Comments:

Milestones MIiestones Planned Revised Actual Case Opened 04/01/2013 04/01/2013 Investigative Plan 04/08/2013 12/01/2014 Revised Approved:

First Investigative 04/15/2013 Step Revised App*oved:

Investigation 08/11/2014 Complete Revised App*oved:

Draft Report to 09/18/2014 AIGI Revised App*oved:

- -- ~- --

Case Closed 09/30/2014 Current approved: 12/30/2016 Revised Approved:

11/14/2016 03:56 PM MIiestone Comments:

Closing Info Management Comments:" This project is being closed and a new project has been initiated. _J Review Comment:

lease let me know why this is being placed in my queue and what if any action you are requesting.

11/12/14) i~?l I did not see the changes to the referral memo for .-07209. Please make changes in memo so OFFICIAL USE ONLY

OFFICIAL USE ONLY that this can be referred. i~f) 10/31/Q.3)

!(b)(?)(C) !Please review the allegations that were correlated to this project. A memorandum to file fo; each allegation should be prepared to reflect your evaluation of each complaint. Additionally, your telephone conve r s ~ information provided by Paul Blanch should be documented and included in this project..~ 5/2/~ 3)

Case Documentation Subject Creator Administration (b)(7)(C)

Investigation Record Investigation Record Comment (Closed )

Investigation Record Comment (Closed )

Investigation Record Comment (Closed )

Investigation Record Comment (Open )

12/12/2016 Case Review (Open) Joseph A. McMilla 07/08/2016 Case Review (Open) Joseph A. McMilla 01/12/2016 Case Review (Closed ) Joseph A. Mc Milla 09/17/2015 Case Review (Open ) Joseph A. McMilla 04/01/2015 Case Review (Open) Joseph A. Mc Milla Request Review:

D Allow Other Readers: Read Authorization:

[Monitor), [All)

(b)(7)(C)

Allegation Status: Closed Allow Olher Editors: NRC, Edit Authorization:

JRC, Status: Closed - .___ _ __,RC Permanent OFFICIAL USE ONLY

OFFICIAL USE ONLY Memos to File Prepared by: !(b)(7)(C) ,06/2812017 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: D

Subject:

A 14 07527 Report Date: 06/26/2017 Narrative: _ J..

Allegation 14-07527_NRC Analyses_Final.pdf Status: Open Allow Other Editors: Edit Authorizalion:

(b)(7)(C)

(b)( )(C) NRC Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0,C. 20555*0001 OFFICE OF THE INSPECTOR GENERAL June 26, 2017 MEMORANDUM TO FILE: Allegation No. A 14 07527 Concur: Allegation Closed ~

Joseph McMillian, Assistant~General for Investigations FROM: r )(7)(C)

Office of the Inspector General

SUBJECT:

Possible Compromise of NAC Analyses Allegation On September 15, 2014, the Office of the Inspector General (OIG), U.S. Nuclear Regulatory Commission (N RC , initiated Allegation 14-07527 based on an e-mail from NRC st~ e (b)(7l(Cl ho received an e-~ public citize (bl(7l(Cl l<bH?HCl I <b < )( re ers o ,mse as "Citizen Watchdog.' (b < alleges that a er reading an nvironmental Impact Statement (EIS) book, e e 1eves NRC uses faulty practices in the EIS licensing process.

Findings OIG determined that OIG Audit Report, OIG-13-A-20, identified areas of current noncompliance and made six recommendations to bring the agency into compliance with 10 CFR Part 51 relative to the preparation of EISs.

Basis for Findings I

OIG reviewed the book referenced byj<b)(7l<Cl The book is titled, "The EIS book:

Managing and Preparing Environmental Impact Statements." Chapter one of the book is titled., "Scientific Facades - How Not to Prepare an EIS and critiques NRC's implementation of the EIS process. The chapter claims that NRC's EIS process is OFFICIAL USE ONLV-OIG INVESTIGATION INFORMATION

OFFIC~AL USE ONLY-OIG INVESTIGATION INFORMATION plagued with "egregious regulatory and legal deficiencies, weaknesses, and flaws" as a result of 11shortcomings in management and oversight.

However, on August 20, 2013, OIG issued audit report number OIG*13-A-20 titled, "Audit of NRC's Compliance with 10 CFR Part 51 Relative to Environmental Impact Statements. The objective of the audit was to determine whether NRG complies with the regulations in 10CFR Part 51 relative to the preparation of environmental impact statements.

In brief, the report identified areas of current noncompliance and made six recommendations to bring the agency into compllance with 10 CFR Part 51 rela1ive to the preparation of EISs. Specifically the audit report stated:

In recent years, NRG has taken steps to enhance its NEPA reviews and procedures. These initiatives have generated fmportant discussions and provide a context for long-term progress. However, the Office of the Inspector General (O/G) has identified areas of noncompliance with 10 CFR Part 51 relative to disclosure and public involvement. In order to clearly communicate the results of and involve the public in its environmental reviews, NRG management should strengthen its EIS preparation process by:

• Publishing a Record of Decision (ROD) that complies with 10 CFR 51.102 and 51.103.

• Publishing an EIS that complies with the format provided in

• 10 CFR Part 51. Appendix A.

• Performing all regulatory requirements for scoping for EISs that tier off of a generic EIS.

Because OIG Audit Report, OIG-13-A-20, addressed short-comings in NRC's EIS process, it is recommended that this allegation be closed to the tiles of this office.

2 OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(7)(C) 106/28/2017 Case Trtle : Special Project: NRC Case Number : C 13 027 Regulatory Oversight Origination Doclink: lj

Subject:

A14 07438 Report Date: 06/26/2017 Narrative:

)...

Allegation 14-07438_RIV lnsp_Final.pdf l(b)(?)(C) Concurred by Name Date 06/28/2017 04:49 PM 1

Status: Open Allow Other Editors: Edit Authorization :

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFfCfAL USE ONLY- OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON DC 205&5-0001 OrFICE OF THE INSPECTOP GENF.AAL June 26, 2017 MEMORANDUM TO FILE: Allegation No. A 14 07438 Concur: Allegation Closed&:  ?

Joseph McMillian, Assistant Inspector Gener for Investigations FROM:

Office of the Inspector General

SUBJECT:

Region IV Manager Failure to Enforce NRC Inspection Manual Chapter Allegation On September 12, 2014, the Office of the Inspector General (OIG), U.S. Nuclear Regulatory Commission NRC , initiated Alie ation 14-07438 via a Hotline submission from RC staff membe (b( l(Cl . l<bl(7J(Cl I states that Branch Chief (bl<7l(Cl violates NRC procedures.

Findings OIG determined that 1<blt7JtcJ Isubmitted a Differing Professional Opinion (DPO) on September 12, 2014, that d1spositioned the same concerns that he alleged to the OIG.

Basis for Findings OIG reviewed thtallegation information provided by l(blt7l(Cl I. l<blt7l<Cl Ibelieves l(bl(7J(c) as violating Inspection Manual Chapter (IMC) 0308. tblt7J(Cl

.....-~-'!'!!"!"'-==:x.:.:c:.:.:

tellingl(b)(?J(C) 7 anged e-mails regarding this matter wit (bl( Jtc) h.:::;

!that he was reporting him to the OIG. - - - - -

,ma e y nd OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION On November 21, 2014, (b C7J(CJ Nuclear Reactor Regulation, issued his decision in a letter 1 < ( concurred with the DPO Panel. He referenced the recommendations (b)(?)(C) In particular, lhe discussed that until actions related to Recommendation 1 are completed.

he described a process to follow when conducting CCDP analysis.

~~.l..l,M.=~i.w.w.WJ.&.1- - - . . . - - - - ' provided to OIG was the same information that nd it was technical in nature, this allegation is

• '='===,..,.....,....-=~=~r=--,~e files of this office.

2 OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(?)(C) 061281201 r 1

Case

Title:

Special Project: NRC Case Number: 'C 13 027 Regulatory Oversight Origination Dodink: [)

Subject:

A14 07515 Report Date: 06/26/2017 Narrative:

ID J..

Allegation 14-0751 S_ACE_Final.pdf Status: Open Allow Other Editors: Edit Authorization:

(b)(?)(C)

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONL"f-OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D,C. 20555.0001 OFFICE OF THE INSPECTOR GENERAL June 26, 2017 MEMORANDUM TO FILE: Allegation No. 14-07515 Concur: Allegation Closaet::::: = =:::::--,..

Joseph McMillian, Assistant Inspector General for Investigations FROM:

Office of the Inspector General

SUBJECT:

Possible Claim of Employee Misconduct by ACE Allegation On August 20, 2014, the Office of the Inspector General (OIG). U.S. Nuclear Regulatory Commission NRC), initiated Allegation 14-07515 based on an e-mail from NRC s 1 (bl(7l<CJ Office of Nuclear Reactor Regulation, (b),:7)(Cl l<bl(7l(Cl I email included letters from Alliance for A Clean Environment perta1n1ng to NAC's oversight of Limerick Nuclear Plant.

Finding Based on OIG's review of information in ACE's letters, OIG concluded NRC provided oversight in accordance with Agency policy and procedures as described in NRC Inspection Manual Chapters, to include IMC 0308 and IMC 0102. Therefore, this allegation was not substantiated and warrants no further action.

Basis for Finding OIG learned from the review of ACE's letters that they are critical of NRC's pretence" of oversight. ACE described several examples of less*than-adequate oversight by NRC, to include: NRC Resident Inspector's (RI) are routinely rotated which leads to loss of institutional memory, the NRC inspection program is narrowly designed, and Rls rely on Licensee's reports and information.

OFFICIAL USE ONL't' -OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG learned through review of documents that NRG Inspection Manual Chapter (IMC) 0308, titled, "REACTOR OVERSIGHT PROCESS BASIS DOCUMENT OR OVERSIGHT PROCESS BASIS DOCUMENT," purpose is to describe the basis for the significant decisions reached by the NRG staff during the development and implementation of the Reactor Oversight Process (ROP) for operating commercial nuclear power plants. This document serves as the source information for all applicable program documents such as manual chapters, performance indicator guidance, and assessment guidance. The objectives of the program are:

• To discuss significant developmental steps and decisions reached.

• To describe in general how the processes work and why they are setup the way they are.

• To summarize the history of, and reasons for, significant changes made to the oversight processes.

• To explain those significant attributes that were initially considered but not used in the ROP, and the basis for the decision not to include them in the process.

Additionally, NRC IMC 0102, titled, OVERSIGHT AND OBJECTIVITY OF INSPECTORS AND EXAMINERS AT REACTOR FACILITIES," describes in general the requirements and guidance to verify employee performance and objectivity by direct observation of on-site activities at power reactor facilities and through other available indirect methods as needed. This IMC also includes RI job duration. Specifically, "All resident inspectors have a 7-year maximum length of tour."

Because NRC's ROP documents describe the programmatic attributes of ROP that ACE has concerns with, it is recommended that this allegation be closed to the files of this office.

2 OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(7)(C ) 0612a12017 1

Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination 0oclink: ~

Subject:

A 13 07194 Report Date: 06/21/2017 Narrative:

Allegation 13-07194_Japan Article_Final.pdf Slatus: Open Allow Other Editors: Edit Authorization:

M (b)(7)(C)

(b)(7)(C)

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLV - OIG INVESTIGATION INfORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINOlON, 0 C 20SS5*0001 O FrlCE or THL INSPECTOR GENE;RAL June 21 , 2017 MEMORANDUM TO FILE: Allegation No. t 3-07194 §_-~ - ----

Concur: Allegation Closed -'-~~.c._---======---:7 Joseph A. McMillan Assistant Inspector General for Investigations FROM: r )(7)(C) I Office of the Inspector General

SUBJECT:

Japan's Article Regarding Byron-Resident Inspector's Behaving Unprofessionally Allegation On March 12, 2013, the Office of the Inspector General (OIG}, U.S. Nuclear Commission (NRC), initiated Allegation 13-07194 from an OIG Hotline submission. A NRC staff member referenced an article in The Japan Times that implied a resident inspector may have acted inappropriately and that the NRC program allowing an inspector at one site for 7 years was also inappropriate.

Finding OIG determined that NRC followed Agency policy and therefore, their actions were appropriate.

Basis for Finding NRC Inspection Manual Chapter (IMC) 2515 establishes the policy for the light-water reactor inspection program. Section 11 .05, titled "Resident Inspector Relocation,"

states, uAll resident inspector assignments will stipulate a seven-year maximum tour length.

TtilS DOCUMENT IS rne f<(') L TV OF THE us NU( L,_ AR REGULA TOR\' COMMISSION, IJ CE OF' TH!: INSPECJQn GENl'RAl (010> IF LOANEP TO ANOTHESl AGENc. V IT ANO ITS CONTENTS ARE. N<.iT .,.v BE REPAOOUCFO OR Ot&TAIOU~ ,.;.L OUlSIOE THF R£CEIVI 111..AGENC'i Wl THOtlT OIG S. Pl:J1MI _,ION

Of ...iCIAL USE 0,\4LY - OIG INVESTIGATION INFORMATION OIG reviewed IMC 2515 and learned the seven year tour length Is based on Commission Policy (i.e. SECY-98-152, "Summary of Issues and Recommended Improvements to the Resident Inspector Program," dated June 29, 1998; Staff Requirements Memorandum, "SECY-98-152, "Summary of Issues and Recommended Improvements to the Resident Inspector Program," dated August 21, 1998; and Implementation of the Seven-Year Relocation Policy for Resident Inspectors, Memorandum from Hugh Thompson to all Regional Administrators, dated September 21, 1998.)" Additionally, on 3/20/13, OIG informed th,e EDO's office that OIG would not review issues pertaining to a resident inspector being assigned to the plant for 7 years.

OIG reviewed The Japan Times article titled, "Toxic Management Erodes Safety at

'World's Safest' nuclear plant." OIG determined that the technical merits of the material discussed in this article were previously considered in OIG Investigation Case 08-012 and were unfounded.

Based on OIG's review of related documents, OIG concluded that NRC's actions are appropriate. Therefore, it is recommended that Allegation 13-07194 be closed.

2 THIS DOCUMENT IS THE PAOPERTV or THE us. NUCLEAR REGULATORY COMMISSION OFFICE OF THE INSPl:CTOR GENERAL tOIG). IF LOANED TO ANOTHER AGENCY. IT ANO ITS CONTENTS ARE NOT TO BE REPRODUCED Oil DISTRIBUTED OUTSIDE Tl-iE RECEIVING AGENCY WITHOUT OIG S PERMISSION OFFiCh.,.L USE O1qLV - OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(?)(C) I 06/28/1017 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: Q

Subject:

A 13 07234 Report Date: 06/21/2017 Narrative:

EiJJII..

. J...

Allegation 13-07234_Limerick_Final.pdf Status: Open Allow Other Editors: Edit Authorization:

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF THE INSPECTOR GENERAL June 21, 2017 MEMORANDUM TO FILE: Allegation No. 13*07234 Concur: Allegation Clos~ =

Joseph McMillian, Assistant Inspector General for Investigations FROM:

Office of the Inspector General

SUBJECT:

Concerns about Limerick Nuclear Plant Allegation On May 23, 2013; the Office of the Inspector General (OIG), U.S. Nuclear ~~llil,,U,,j...---,

Commission NRC 'nitiated I i

• 4 * * <b < l< l (b)( )( )

Cbl<7J(C) Office o the Executive Director for Operations, U.S.

uc ear egu a ory omm1ssion. (bJ(7J<cJ rovided

• nse on,.,.,..,.

th=e~__,

Limerick correspondence to (b)(7)(C) letter. (b)(?)(C) is thel(b)(7)(C) of Alliance For A Clear Environmen . (b)(7)(C) alleged complicity and negligence regarding violations of NAG regu at,ons in a wi e variety of areas related to Limerick Nuclear Power Station.

Finding Based on OIG's review of documents discussed in ~(b)(?)(C) Iallegations, OIG concluded NRC provided oversight in accordance with Agency policy and procedures.

Therefore, these allegations were not substantiated and warrant no further action.

Basi-s for Finding Exelon*s Limerick Station, a two unit site, produces 2,345 net megawatts of electric power. Units 1 and 2 draw its cooling water from the Schuylkill River. Limerick Unit rs OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLV -OIG INVESTIGATION INFORMATION original license continues through Oct. 26, 2024 and Unit 2's license continues through June 22, 2029. Currently, Limerick Station has pending license renewal applications for both units.

b 7 c described ACE's c ncerns in a letter to l(bl(7l<Cl I (b)C7l(Cl U.S. Nuclear Regulatory Commission, dated April 29, 2013. In the letter, (b)(7)(C) notes that he is aware that NRG received a copy of ACE's March e-mail to Con ressman !(b)(7)(C) Iexpressing concerns about Limerick Nuclear Plant. In total, {b){7)(C) describes ei hteen concerns. Also. !(b)(7)(C) I discusses NRC's mlsree esentation to !(b)(7)(C) 1 regarding the relationship between NRC and ACE. !(b)(7)(C _ Ialludes that NAG is not as responsive to the public as its public relations statements would like everyone to believe. In addition !(b)(7)(C) I suggests that NRG meets regularly with Exelon and lobbyists.

7 res s e t n e-mail to l(b){7)(C) I dated May 16, 2013, fro (b)(?l( l (bl( l(C) Division of Reactor Projects, NRC Ref ion i Office regar ing t e tn orma ,on Ll,;;,L,l.;.J.l.;;.i.,.._____. provided to Congressman !(b)(7)(C I Additionally in the e-mail,~ addressed three concerns !(b)(7)(C) Idiscussed during the March 27, k~~ ~()m5Jic""ar\nual assessment OP.en house regarding Limerick Station. Furthermore, extended an opportunity to !(b)(7)(C) Ito discuss all his concerns before or between the May 23, 2013 public meeting where NRC headquarters staff would discuss and receive comments on the draft Supplement 49 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437) for Limerick Generating Station.

Upon OIG's review of the material related to this allegation, OIG found disagreements pertaining to the staff's handling ot various technical issues rather than specific claims of misconduct or failure to implement NRG policies properly. All eighteen technical concerns identified by ACE have been addressed by the NRG via numerous means including e-mails, letters, and one-on-one conversations.

Also the NRG has extensively communicated with ACE as deimonstrated by the following:

• A May 9, 2012, email from !(b)(?)(C) ho ACE responding to your questions from the April 18, 2012, annual assessment meeting regarding Limerick Generating Station (Limerick) performance.

A March 8, 2013, email from (b)(7)(C) to ACE responding to an ACE email dated March 5, 2013, regarding the power up-rate and license renewal review processes.

• A March 20, 2013, e,mail from l(b)(?)(C) Ito ACE responding to an ACE email dated February 27, 2013, regarding low level radioactive waste storage and shipping associated with Limerick.

• A May 3, 2013, email from (b)(7)(C) to ACE responding to an ACE email dated April 5, 2013, regarding spent ue and low level waste associated with Limerick.

2 OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION

• A May 10, 2013, email from l(b)(?)(C) Ito ~ and t(b)(7)(C) I responding to questions regarding the August 2011 Virginia earthquake and its impact on Limerick.

• A May 16, 2013. email from !(b)(7)(C) !to ACE responding to questions and statements from ACE received in March 2013.

• A June 4, 2013, letter from (b)(7)(C) to ACE regarding your concerns with the Limerick evacua1ion time es 1ma e up ate.

Furthermore, OIG learned NRG staff also spoke with !(b)(7)(C) Iat the May 23, 2013, NRC public meeting held to discuss the draft supplemental environmental impact statement for the license renewal of Limerick. This one*on-one conversation dealt with comments !(b)(7)(C) Ihad made at an earlier time regarding the environmenta, impact statement scoping process.

Regarding !(b)(7)(C) Iobservations that NRC meets regularly with Exelon management, OIG found that the NRC is within policy for keeping the public informed of agency activities. In Management Directive (MD) 3.5, Attendance at NRG Staff*

Sponsored Meetings, in Section 11,C.2., "drop*in" meetings or similar management meetings are discussed. It states, "Senior executives of a licensee, applicant. or a potential applicant request the opportunity to conduc.t a "drop-in" visit or similar management meeting with the EDO, with other senior managers at agency headquarters, or with senior managers of the region in which their facility is located.

Because these visits or meetings are usually limited to a generijl exchange of information not directly related to any regulatory action or decision, they would not typically be public meetings."

Based on OIG's review of documents discussed above related to !(b)(7)(C) allegations, OIG concluded that the allegations were not substantiated and warrant no further action. It is recommended that Allegation 13-07234 be closed.

3 OFF1CtAL USE ONLY- OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(?)(C) I 06/2812017 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink : CJ

Subject:

A 14 07342 ReportDate: 06/21/2017 Narrative:

E::111...

J...

Allegation 14-07342_Emergency AC Power_Final.pdf Status: Open Allow Other Editors: Edit Authorization:

Request Review:

Approval.

OFFICIAL USE ONLY 1

OFFICIAL USE ONL"I-OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 OFFICE OF Tlt:

INSFF.CTOfl GENEAAL June 21, 2017 MEMORANDUM TO FILE: Allegation No. A 14 07342 Concur: Allegation Closed _ _.__.____ _-----=:::::::,

Joseph McMillian, Assistant Inspector General for Investigations FROM: r )(7)(C)

Office of the Inspector General

SUBJECT:

NRC's Handling of an Operability and Regulatory Non-Compliance of the Emergency AC Power System at the Oconee Station Allegation On November 20. 2013, the Office of the Inspector General (OIG), U.S. Nuclear Commission (NRC), initiated Allegation 14-07342 from an anonymous allegation received by the OIG "Oversight of Active Component Aging Audit Team." This allegation has two areas of concern. For area one, the ALLEGEA claims that NRC may not have pursued and addressed an operability issue and regulatory non-compliance at Oconee Station involving the emergency AC power system, also known as the Keowee Hydro Units (KHUs.) Specifically, the ALLEGER is concerned whether the licensee had conducted an operability evaluation of Oconee's safety-related emergency AC power sources that are potentially degraded, and whether the NAC pursued an inquiry and assessment of the licensee's operability evaluation.

OFFICIAL USE ONL't'-OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION For the second area, the ALLEGER is also concerned that the NRC is allowing the Oconee units to operate with the KHUs in a degraded state due to the aged windings, which may be contrary to NRC requirements and regulations.

Findings OIG determined that the Licensee submitted a License Amendment Request (LAA) involving the emergency AC power system, also known as the KHUs. This LAA discussed the operability concerns during the maintenance of the KHUs as well as describing overhauls ot the windings. The staff subsequently documented the approval of the LAA In a Safety Evaluation Report.

Basis for Findings The ALLEGER, who reque sted anonymity, is an NRC system expert and is knowledgeable in major equipment issues including equipment failures caused by age-related causes. The ALLEGER provided additional information in an attachment.

OIG learned that Resident Inspectors (RI) review operability evaluations as part. of the Reactor Oversight Process (ROP). As defined in ROP, inspectors do not review every operability determination but review a sample set. Additionally, If the Al's have no findings, they are not required to report the details of their review in inspection reports.

However, Rls communicate Licensee activities on a daily basis to the Region and routinely to NRC headquarters.

OIG learned that on June 27, 2012, the Licensee submitted an amendment request to allow the two Oconee KHUs to be inoperable for a period longer than the currently allowed by the technical specifications. On January B, 2014, the NRC issued Oconee an amendment regarding temporary technical specification a change request to extend the completion time for an inoperable KHU. Included in the staff's Safety Evaluation Report (SER), and appearing to be the basis for meeting reasonable assurance, are Regulatory Commitments and not License Conditions. Regulatory Commitments are not enforceable and not specifically discussed in ROP.

Additionally, OIG learned that a similar LAA was submitted and approved In the 2008 timeframe and the current NRC staff used the 2008 LAA as a reference.

OIG learned that both KHUs were to be overhauled during this outage. Both KHU units are operating past 40 years.

Because NRC docketed a Safety Evaluation Report that addressed the concerns described in this allegation. it is recommended that this allegation be closed to the files of this office.

2 OFFICIAL USE ONL't' - OIG INVESTIGATION INFORMATION

OFFiCIAL USE ONLY Memos to File Prepared by: l(b)(?)(C) I 06/28/1017 Case Title : Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink : CJ

Subject:

A 14 07379 Report Date: 06/21 /2017 Narrative:

Elll*

Allegation 14-07379_ R11 Staff_ Final.pdf Status: Open Allow Other Editors: Edit Authorization:

(b)(?)(C)

(b}(?)

(C)

Request Review:

Approval.

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION UNITED STATES NUClEAR REGULATORY CONIM,SSION

,\IA~I H-lt. TON O C 2'0S5S-000 OFFICE <Jr THI:

INSPECTOR GWER,\L June 21 , 2017 MEMORANDUM TO FILE: Allegation No. A 14 07379 . c------,.,_...,_ __

Concur: Allegation c~ <=-7 Joseph McMilllan, Assistant Inspector General

- - -----=--

for Investigations FROM:

Office of the Inspector General

SUBJECT:

Former Duke Contractor Alleges All Staff Improperly Closed Allegation Allegation On February 12, 2014, the Office of the Inspector General (OIG), U.S. Nuclear Regulatory Commission (NRC), initiated Allegation 14-07379 from an OIG Hotline submission. A former Duke Energy contractor named, !(b:,17l(C) I alleged that the NRC Region II staff improperly closed his safety allegation regarding his seismic engineering work at the Crystal River Nuclear Plant in August and September of 2012.

Specifically, the NAC did not review his technical calc ulations and only accepted the Licensee's calculations.

Findings OIG determined that Region II followed the Agency Allegation Process which included having al(bX7 J(CJ Iperform independent engineering calculations for the safety related batte stora e racks and he compared hi

• ent results with the analysis provided by (bJC?J(Cl The NRG .determined that (blC7lCC) had an error in his calculations and the Licensee's tie-rods did meet the seismic qualifications. Therefore, the statement that the NRC did not follow the Allegation Process and review the technical information he provided was not substantiated.

OFFICIAL USE ONL'.' -OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY-OIG fNVESTIGATtON INFORMATION Basis for Findings stated that the safety-related battery storage racks do not meet the seismic asis. He stated that the Licensee1s calculation had errors. Specifically,

- e-s,-g-n .........

!(b)(?)(C) !noted that the ti 0 -4~s were not attached on lower decks of batteries like they were on the upper decks. F l<l< . asserted that his calculations demonstrated that seismic requirements are not met with this tie-rod arrangement.

OIG learned that on June 7 , 2013, the NRC sentl<bl(?)(C) Ia response letter which concluded that there were no operability concerns with the battery rack A Region IV Technical Expert performed a review of the Licensee's calculations and concluded that the battery racks adequately met seismic requirements.

On August 26, 2013J bl<l(Cl 7

Iresponded to the NA~ letter saying that the involved calculations were not correctly considered.l(b)(?)(C) included an interpretation of various documentation, as well l ~l/?(t) 7 soeTfic calculation he had used to identify a breach in seismic requirements. . _ modeled the rail as a simple span for force calculation purposes.

l(b)(?)(C) I On November 26, 2013, responded to...._ ____,with Allegation Report Rll -2013-A-0121 . OIG learned that a Region IV Te

• ert conducted a11 independent review of the additional information provided b (b)(?)(C) and compared his results with

<o)(?J(cJ results. The NRC (b)(7)(C) analyzed the beam using the avallable ocumen a ion from the Crystal River plant1 and had determined that It would most accurately be modeled in a calculation as a continuous beam.

Ito review In June 2015, (b < l aspects o Together. (bJ(?J(CJ and NAC {~W)(C) r::::i:

met with the NRC l(b)(?)(C) c uaing thri ~~tt~~ line calculations.

performed the seismic calculations or sa e y-re a e a ery storage ra . e I I trans were performed using a continuous beam model but with the standards provided byl16l<7l(Cl I For exampleJ(bJ(?)(Cl I Beam Diagrams and Deflections Tables of the American Institute of Steel Construction. The results were that the lower battery racks were adequately designed to meet the seismic requirements.

Based on OIG's review of documents discussed above related tol(b)(?)(C) Iallegation, OIG concluded that the allegations were not substantiated and warrant no further action. It is recommended that Allegation 14 07379 be closed.

2 OFFICIAL USE ONLY -OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: !(b)(?)(C) I 06/28/2017 Case

Title:

'Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Docllnk: Q

Subject:

A 14 07513 Report Date: 06/20/2017 Narrative:

Eilll Allegation 14-0751 3_R111 Staff_Final.pdf Status: Open Allow Other Editors: Edit Authorization:

(b)(?)(C)

(b)(?)(C) C Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY' -OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON DC. 20SSS-000f OFFICE OF THE INSPECTOR GENEflAt..

June 20, 2017 MEMORANDUM TO FILE: Allegation No. A 14 07513 ,

Concur: Allegation Closed ~ -

Joseph McMillian, Assistant Inspector General for Investigations FROM: 1 117J<CI Ottice of the Inspector General

SUBJECT:

NRC Region Ill Management Disregard of NRC Inspection Manual Procedures Allegation On August 21, 2014, the Office of the Inspector General (OIG), U.S. Nuclear Regulatory Commission (NRC), initiated Allegation 14-07513 based on information submitted via the OIG Hotline. An anonymous complainant alleged that NRC Region Ill Senior Management flagrantly disregarded NRC procedures and processes. Specifically, the NRC issued a final Greater-than-green finding to the Fermi nuclear plant for a security issue. Approximately 60 days after the finding was identified, the Licensee provided the NRC with additional information that Region Ill Senior Management required the staff to consider. NRC policy and procedures describe a 30 day limit in the appeal process tor Licensee's additional information.

Findings OIG substantiated that notwithstanding the failure to meet the criteria established in Inspection Manual Chapter (IMC) 0609, Attachment 2 , NRC Region Ill management did agree that the additional information may affect the signmcance of the issue and associated finding and the NRC did include the additional information in their review.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION Basis for findings OIG learned from the information provided by the Alleger that on May 29, 2014 (EA 022). the NRC issued a final Greater*than-green finding to the Fermi nuclear plant for a security issue. Despite NRG Inspection Manual Chapter 0609 guidance, NRC Senior Management instructed the staff to evaluate the new information and its impact on the finding's significance. The NRC Inspection Manual Chapter instructed the NRC staff and management to deny the appeal based on two factors: ( 1) the appeal was not timely and (2) the additional information was not identified by the licensee during official proceedings. In fact, the Licensee did not question the measurement at any time during the proceeding.

On December 6 2016, OIG interviewed, (bl(7)(Cl RIii Senior Manager. who was the manager identified In the allegation. (bl(7l(Cl acknowledged that RIii management did allow the Licensee to provide additio ation past the 30-day limit for appealing determinations of significance for the Greater than Green finding.

Additionally, the RIii Management knew the Licensee's request to provide the additional information for NAC consideration did not meet the criteria established in IMC 0609. . HoweverJ<bl<7 J<cJ !explained that NRG Inspection Manual Chapter 0609 does not prohibit NRC managers from accepting information past the due date. He stated that the NRC mission is to ensure public health and safety and prudent to consider all information. And, the additional! information did not change the previously determined security significance of the find. (bl<7J(Cl iterated that the NRG staff documented the additional time allotted to provi e information was described in the October 8, 2014 NRC letter to the Licensee titled, FERMI POWER PLANT, UNIT 2, REQUEST FOR APPEAL AND ADDITIONAL INFORMATION REGARDING GREATER THAN GREEN FINDING AND NOTICE OF VIOLATION 05000341/2013408-01.

Also, OIG learned from l(b)(?)(Cl hhat he has since addressed and discussed with his management team the importance of communication.

Because the NRC addressed the concerns of the alleger transparently within the enforcement letter to the Licensee, it is recommended that this allegation be closed to the tiles of this office.

2 OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(7)(C ) l 06/28/2017 Case

Title:

S pecial Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Dodink: [)

Subject:

A 13 07193 Report Date: 06/15/2017 Narrative:

E:'Jal..

Allegation 14-07193_Xcel Prairie_Final.pdf Status: Open Allow Other Editors: Edit Authorization:

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMfSSION W\~HINGlON O C. 2<15SS*OOCII OFFICE. OF THE lt~SflECl'OR CENEAAI.

June 15, 20:1 7 MEMORANDUM TO FILE: Allegation No. A 13-07193 Concur: Allegation Closed~:::.:"'*),__====--

Joseph McMillian, Assistant Inspector General for Investigative Operations FROM: l(b)(?)(C) I Office of the Inspector General

SUBJECT:

Non-Working Monitor at Xcel Prairie Island Nuclear Station Allegation On November 20, 2013, the Office of the Inspector General (OIG), U.S. Nuclear Commission NRC initiated Allegation 13-07193. The allegation was received by the OIG from (b)( K ) who wa (b)( (C n enforcement Regulatory Conference on a potential white finding or raine Island Nuclear Station. j""" (b""'j(?,.,,

j(c,...

) --,

!(b)(?)(C) Ireceived an e-mail written by stakeholder David LOCHBAUM that describes the NRC as over-reacting to the Praire Island nonworking radiation monitor.

Findings OIG determined that the NRC's issuance of a white finding was based on violatlons associated with 10 CFR 50.47(b)(4) and (b){8) per Agency enforcement policy.

Therefore, the statement that the NRC was over~reacting is not substantiated.

Basis for Findings OIG learned that LOCHBAUM authored an e-mail on February 25, 2013. In this e-mail, LOCHBAUM stated that based on his review of documents in ADAMS, "The impression I get from the documents is that Xcel used up its 11get out of jail free" card with the NRC in the 201 O matter. Put another way, had any other plant owner been found to have OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION

OFFICJAL USE ONLV - OIG INVESTIGATION INFORMATION done the same thing that Xcel did at Prairie Island Unit 1 in 2011/2012, I doubt the NRC would have even thought about imposing a White findlng. Xcel seems to be paying a price now for irking NRC then."

OIG learned that a Regulatory Conference was held on February 25, 2013 with the Licensee. The Licensee agreed with the performance deficiency. The Licensee attributed the root cause of the failure to a mindset which did not recognize that the 1R-50 shield building high range vent gas radiation detector was a single piece of equipment necessary for emergency preparedness action levels and did not recognize its importance to the emergency preparedness program.

OIG reviewed a document dated March 26, 2013. The document states, "the NRC issued a Notice of Violation to Northern States Power Compariy, Minnesota tor a violation 0110 CFR 50.54, "Conditions of Licenses," and risk significant planning standards 10 CFR 50.47(b)(4) and (b)(B) associated with a White Significance Determination Process finding. The finding involved the failure to recognize that the 1R-50 shield building high range vent gas radiation detector at Prairie Island Nuclear Generating Plant (Prairie Island) was a single piece of equipment necessary for emergency preparedness action levels and failure to recognize its importance to the emergency preparedness program. Specifically, from July 24, 2011, to May 18, 2012, the 1R-50 high range detector was inoperable, which degraded Prairie lsland 1s ability on Unit 1 to classify and declare general emergencies or site area emergencies. Prairie Island did not take timely corrective actions to restore the monitor, which is a piece of equipment necessary to support the emergency preparedness program."

Because NRC's issuance of a white finding was in accordance with Agency policy, this allegation is unsubstantiated and it is recommended that this.allegation be closed to the files of this office.

2 OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: !(b)(?)(C)  ! 06/28/2017 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Dodink: [)

Subject:

~!legation A 15-07582 Report Date: 06/15/2017 Narrative:

Allegation 15-07582_FSARs_Final.pdf Concurred by Name Date

,.,,.l (b.,.,,

)(7"""

)("""

C)- - - , 06/28/2017 04:48 PM Status: Open Allow Other Editors: Edit Authorization:

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLV - OIG INVESTIGATION INFORMATION UNtTEO STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2056S-0001 OFFICE OF THE INSPECTOR GENCRl\l June 15, 2017 MEMORANDUM TO FILE: Allegation No. A 15-07582 -..::-..::-..::-..::-..::-..::-..::-~.:::------

Concur: Allegation Closed ~

Joseph McMillian, Assistant Inspector General

=-::,

for Investigations FROM:

Office of the Inspector General SUBJECT; Delays In Making FSARs Publicly Available Allegation On December 5, 2014, the Office of the Inspector General (OIG), U.S. Nuclear Regulatory Commission (NRC), initiated Allegation 15-07582 based on Information received from stakeholder Mr. David LOCHBAUM. LOCHBAUM alleged that the NRG inconsistently made available to the public in ADAMS. licensee's Updated Final Safety Analysis Reports (UFSAR).

Findings OIG determined that the NRC did recognize that the public access to UFSAAs was inconsistent and issued regulatory issue summary (AIS) 2015-17 with further guidance.

Basis for Findings OIG learned from the review of information provided by LOCHBAUM that UFSAR material is essential to the public. He said that UFSAR material summaries the design features that comply with federal regulations and the safety studies that show the design meets all federal regulations that protect the public. Also, the public needs access to UFSAA information to participate meaningfully in NAC licensing and decision-making processes.

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLV - QIG INVESTIGATION INFORMATION OIG learned that on June 15, 2015, the NRC Commission issued Staff Requirements Memorandum (SAM)-SECY-15-0032, "Reviewing Documents for Public Release Using Sensitive Unclassified Non-Safeguards Information Guidance" which discussed public access to UFSARs.

OIG learned that on December 23, 2015, the NRC issued RIS 2015-17. Titled, "REVIEW AND SUBMISSION OF UPDATES TO FINAL SAFETY ANALYSIS REPORTS, EMERGENCY PREPAREDNESS DOCUMENTS, AND FIRE PROTECTION DOCUMENTS." This RIS was to remind licensees of the review and submission requirements of 10 CFA 2.390, "Public Inspections, Exemptions, Requests for Withholding, regarding information that may be withheld from public disclosure, as well as to recommend that the updates to Final Safety Analysis Reports (FSARs) required by 10 CFR 50.71 (e) be made electronically on a total FSAR replacement basis, as described ln 10 CFR 50.4(b)(6). This AIS states:

Specifically, the NRG is issuing this RIS for the following purposes:

(1) To remind licensees of the potential for physical protection information, which the NRG is required to protect in the same manner as commercial or financial information for the purposes of withholding from public disclosure pursuant to 1o CFR 2.390(d)(1). to becontained in documents that will be proactively released to the public in accordance with the Commission direction in Staff Requirements Memorandum (SRM)-SECY- 15-0032. Specifically, the NRG re.minds licensees of the potential for physical protection in.formation to be contained in Preliminary Safety Analysis Reports (PSARs). FSARs. FSAR updates, and in emergency preparedness and fire protection documents, which had previously been presumptively withheld by the NRC_

(2) To recommend a format for submission of FSAR updates for nuclear power reactors. Other Part 50 licensees are not required to update its facility FSARs, unless applying for renewal of the facility license. Licensees have two submission format options regarding FSAR updates: (1) efectronically on a total FSAR replacement basis, as described in 10 CFR 50.4(b)(6), or (2) on a paper replacement page basis, as described in 10 CFR 50. 71 (e). Electronic submission of updates on a total FSAR replacement basis would save billable staff hours since time would not be taken to manually reconstruct sections of the FSAR for various staff reviews. Therefore, the NRG recommends that licensees voluntarily submit updates electronically (via CD or Electronic Jnformatjon Exchange) on a total FSAR replacement basis. Submission of FSAR updates in this manner will a/so assist the NRG in its emergency response function by ensuring recently-updated, total FSARs are available to NRG emergency response teams.

Because NRC's issuance of RIS 2015-17 addressed LOCHBAUM's concern of public access to UFSARs 1 this allegation Is recommended to be closed to the files of this office.

2 OFFICIAL USE ONLV-OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(7)(C) I 01/27/.2017 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulato ry Oversight Origination Doclink: lj

Subject:

Case File Closure Memo Report Date: 01 /27/2017 Narrative:

ii CTF_Project 13 027_Jan 2017.docx Concurred by Name Date

... z}-<C....}....I

,,b-}<""" 01/27/2017 04:57 PM Status: Closed Allow Other Editors: Edit Author1zat!on:

Request Review:

Approval:

OFFICIAL USE ONLY 1

O FFICIAL USE ONLY - OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555.()001 May 14, 2018 MEMORANDUM TO: Concur: Case Closed Joseph A. McMillan Assistant Inspector General for Investigations FROM: l(b)(7)(C)

Office of the Inspector General

SUBJECT:

Special Project: NRC REGULATORY OVERSIGHT (OIG CASE NO. 13 027)

Recommendation (b)(7)(E)

This project is being closed and a new project with the same objectives has been reopened in fiscal year 2017.

Project Conclusion This project was initiated in April 2013 as a mechanism to identify potential investigative matters associated with NRC technical and regulatory oversight where individual misconduct was not identified as a concern. Over the course of this project a number of technical issues were evaluated, to include the following issues:

• Proactive Initiative: Review of NRC's Handling of Security Inspection Program (C 14 012)

• Potential Lack of Oversight of Water Leakage and Safety Culture at Palisades Nuclear Power Plant by Region Ill (C 12 056)

• Failure to perform NRC Inspection Requirements By Region II (C 15 041)

• Concerns Pertaining to NRC Staff Handling of Regulatory Issue Sull'mary (C 16012)

• Misuse of Funds Pertaining to an lnteragency Agreement Between NRC and Oakridge National Laboratory (C 16 013) ,

TiilS DOCUMEl'fT IS THE PROPERTY OF THE U.S. NUCLEAR REGVLATORV COMMISSION, OFFICE OF THE INSPECTOR GENERAL(OIG). IF LOANED TO ANOTHER AGENCY, IT AND ITS CONTENTS ARE NOTTO ae REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY - OIG INVESTIGATION

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION In addition, four investigations were initiated:

• NRC Oversight of St. Lucie Nuclear Power Plant Main Steam Isolation Valves During Component Bases Inspection Process (C 15 013)

• Lack of Rigorous Oversight By the NRC Concerning Plant Problems at Fort Calhoun Station (C 13 042)

• Failure 1o Identify Potential Problems With a Safety Relief Valve During a Component Design Inspection at Pilgrim Nuclear Power Plant (C 15 029)

• Indian Point Provided False Information to NRC Regarding Algonquin (b)(7)(E)

Incremental Market Natural Gas Project (A15 07602)

Further, during the course of this project a number of allegations were monitored for potential development but did not necessarily cross the threshold for an allegation, investigation, or a project:

• Possible Compromise of NRC Analyses (A14-07527)

• Lack of Rigorous Proactive NRC Investigation (A13-7185)

• Non-Working Monitor at Xcel Prairie Island Nuclear Station (A13-7193)

• Japan's Article Regarding Byron- Resident Inspector's Behaving Unprofessionally (A13-7194)

Finally, the following three allegations hav.e been closed out:

• Lack of Rigorous Proactive NRC Investigation (A13-7185)

• Lack of Rigorous Oversight By NRC of Plant Problems at The Fort Galhoun Station (A13-7192)

• Concerns regarding NC State Laboratory (A13-7301)

The following technical investigations A RUfl'!Gor of tho toGhRiGal Investigations ~es t-Rat were supported during ffi this project and will continue to be supported e\1ahe1al0a during the IR4Ae-rnext project~. Tt:lls iR~M-follGwiA!}-lssues;

• Concerns Regardirng Release of Radioactive Material into the Groundwater at Indian Point Nuclear Generatin Units C 16 016

• (b)(?)(A)

• (b)(?)(A)

• (b)(?)(A) 6 032 THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIG). IF LOANED TO ANOTHER AGENCY, IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT O IG'S PERMISSION.

OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION

• NRC Management Pressure to Administer Reactor Operator Examinations Pertaining to New Reactor Sites (C 16 033)

• r In addition +!he following allegations were correlated to this pro,ect and will continue to be evaluated QQling_iA the next project:

)(7)(A)

• .(b)(7)(A)

• Concerns that AP1000 Shield Building Fails to Meet Seismic and Aircraft

• armer u econ rac or a eg,es s a improper y c ose a ega I0n A 14 07379)

• Concerns Regarding Nuclear Fuel Services Process of Uranium Hexa-Fluoride (A 14 07535) l(b)(7)(A)

Distribution:

Case File 13-027 Magnum OIG OIG OIG OIG OIG (b)(7)(C) I J. McMillan D. Lee H. Bell (b)(?)(C) I I /17 I /17 I /17 I /17 I /1 7 Official File Copy OIGIAIGI Form 714 Revised: Janual)l 2016 3

THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIGI, IF L OANED TO ANOTHER AGENCY, IT AND rrs CONTENTS ARE NOT TO BE REPRODUC.ED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSIOJ'I, OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: LJ

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Case 16 016 Report Date: 11/13/2016 Narrative:

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Regulatory Oversight Originati,....,;,,.;;;.;,...._.........,.,

Subject:

Report Date: 11/13/2016 Narrative:

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..,,..,.,.,,.,.,..---, Concurred by Name l(b)(7)(C) 11/13/2016 09:49 AM Date Concurred by Name Date ffl'l (b""')

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Case 14 012 Report Date: 06/30/2016 Narrative:

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Case 16 032 IMC 1245 Report Date: 06/13/2016 Narrative:

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l (b)(7)(C) I REVIEW CASE FILE NUMBER 13 027 NRC Office of the Inspector General PAGE 1 OF 1 PAGES DETAILS Memorandum to File Summary of Contact (b)(7)(A ),(b )(7)(C)

\D/(1 }\~) INAME I SIGNATURE DATE May 12, 2016 REVIEWER NAME I SIGNATURE DATE THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF TliE INSPECTOR GENERAL (OIG). IF LOANED TO ANOTHER AGENCY, IT ANO ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: March 2016

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Case 16 032 Report Date: 06/07/2016 Narrative:

Duplicate Concurred by Name Date

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Case 16 032 Report Date: 05/27/2016 Narrative:

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Turkey Point "Unusual Event" Report Date: 03/23/2016 Narrative:

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Proactive Initiative - Callaway Report Date: 12/01/2015 Narrative:

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C__ ) _ _ _ _ _I REVIEW CASE FILE NUMBER 13 027 NRC Office of the Inspector General PAGE 1 OF 4 PAGES DETAILS Memorandum to File

Subject:

As a proactive initiative,~and OIG Engineering Intern has followed the unexpected trip at Callaway Nuclear PoweTPlariio'n August 11, 2015, due to a wiring error for the main transformer.

While responding to this trip, the Licensee found that one of the two safety-related, motor-driven auxiliary feedwater flow control valve could not perform its safety function. It was also determined that these control valve~ have a history of inoperability and have*exceeded technical specifications in the past.

OIG learned that NRC complete9 a "post maintenance inspection" of one of the motor-driven auxiliary feedwater flow control valve in December 2014 and reported no findings.

Below is a summary of documentary information reviewed to date:

Timeline Oct. 2014 - MD 8.3- Maintenance performed on ALHVOOll. The setting of a valve potentiometer was not verified following maintenance.

October 23, 2014 - MD 8.3 - The bridge rectifier was modified on a control card for valve ALHV0007 November 15, 2014 - MD 8.3- The bridge rectifier was modified on a control card for Valve ALHV0005.

December 3, 2014 - MD 8.3 - Valve ALHVOOOS did not close fol lowing a plant trip because the bridge rectifier failed.

December 3, 2014 - MD 8.3-The li censee replaced the ALHV0005 Control card with another having a similarly modified bridge rectifier.

December 4, 2014 - NRC inspection 2014005, Included post-maintenance inspection of motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs July 23, 2015 - MD 8.3 -ALHVOOll closed and failed to reopen following a reactor scram.

August 11, 2015- MD 8.3 -Valve ALHV0007 closed following a plant trip but did not open upon demand because the bridge rectifier failed.

THIS DOCUMENT IS THE PROPERTY' OF THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL IOIG, IF LOANED TO ANOTHER AGENCY. IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIOE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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)_ _ _ _ __,1 REVIEW CASE FILE NUMBER 13 027 NAC Office of the Inspector General PAGE 2 OF 4 PAGES August 11, 2015 - MD 8.3 - The control card for ALHV000S was replaced with a properly modified card.

Sept 19 - NRC special inspection, non-cited violation for declaring the system operable witho ut fully understanding the failure mechanism.

Summ.ary of 2014 Card failure, ALHV000S

- In October and November 2014, two auxiliary feedwater valves were fitted with new control valve control cards. These cards were reverse engineered by a vendor (Nuclear Logistics), from the existing cards. The bridge rectifiers used in the original cards were unavailable due to obsolescence, so new ones were made and used.

- A Plant trip caused valve ALl*W000S (same component type as the 2015 card failure, ALHV0007) to fail, one month after installation of the modified cards. The bridge rectifier was found to be damaged, and the card was determined to have failed due to an "infant mortality" issue. The failed card was replaced by an identical card.

- Post-maintenance testing o1fthe replaced card, as well as surveillance testing of both cards until the 2015 plant t rip did not expose any failure conditions to the cards.

- NRC inspection 2014005 was conducted and included post-maintenance inspection of motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs. No findings were identified.

- In response to the 2014 card failure, Nuclear Logistics designed new modified bridge rectifiers with increased amperage ratings for the cards, which were installed for both auxillary feedwater valves, but the ALHV000S and 0007 cards were allowed to remain in use until the next refueling cycle in 2016.

THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION. OFFICE OF THE INSPECTOR GENERAL (OI G)

IF LOANED TO ANOTHER AGENCY, IT ANO ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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Summary of 2015 Card Failure, ALHV0007

- On August 11, 2015, a grid disturbance caused a turbine and reactor trip at Callaway plant and initiated Auxiliary Feedwater System actuations. All systems involved in the reactor t rip initially responded as expected. Approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following the trip, while attempting to transfer t o the motor-driven auxiliary feedwater pumps, flow control valve ALHV0007, wou ld not respond to "open" demand signals from t he control room.

- The bridge rectifier was again found to be damaged.

- According to the licensee, the operating temperatures affected*performance of the cards, and placed them in unexpected operating conditions

- New cards from Nuclear Logistics with the increased amperage rating rectifiers were installed for both ALHV000S and 0007.

- NRC conducted a special inspection on Sept 19, and issued a non-cited violation for declaring the system opera ble without fully understanding the failure mechanism. A partial systems walkdown was performed, no findings were identified.

NRC lrnspection report data:

1. Inspection Report 2014005; P.15, post-maintenance inspection scope

a. December 4, 2014, motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs, Job 14006195. The inspectors reviewed licensing- and design-basis documents for the structures, systems, and components and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, and components. These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings: No findings were identified.

2. Special inspection Report 2015003 Cornerstone: Mitigating Systems. Green.

THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION. OFFICE OF THE INSPECTOR GENERAL (OIG)

IF LOANED TO ANOTHER AGENCY, IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGEN CY WITHOUT OIG'S PERMISSION.

OFFICIALUSE ONL't'-OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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The inspectors Identified a non-cite*d violation of 10 CFR Part so, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensee's failure to follow their operability determination procedure.

Specifically, when an auxiliary feedwater control valve failed to operate from the main control room, the licensee failed to evaluate the operability of the component in accordance with Procedure ODP-ZZ-00001, Addendum 15, "Operability and FunctionaHty Determinations." The immediate corrective action taken by the licensee was to evaluate the operability of the flow control valve. After determining that the equipment was inoperable, the licensee entered the required technical specification condition and performed the required technical specification actions. The licensee entered this issue into their corrective action program as Callaway Action Request 201502708.

This performance deficiency is more than minor and, therefore, a finding, because, if left uncorrected, it has t he potential to lead to a more significant safety concern if safety-related systems are not properly evaluated for operability. The finding affects the Mitigating System Cornerstone because the performance deficiency is related to the auxiliary feedwater system's ability to conduct short-term decay heat removal.

Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions,"

the finding was determined to be of very low safety significance because it did not affect system design, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed o utage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. This finding has a cross-cutting aspect of challenge the unknown in the human performance cross-cutting area because the licensee did not stop when faced with uncertain conditions. Specifically, rather than declaring the system inoperable and allowing the process to evaluate the condition; the licensee declared the system operable without fully understanding the failure mechanism [H.11]. (Section lRlS)

Attached Documents:

1. Licensee Event Notification

2. Licensee Event Report (LER), October 1, 2015

3. Licensee Event Report (LER), October 12, 2015 (b)(?)(C) I

!NAME\ SIGNAT~RE DATE (0)(/)(\_;J 12/1/2015 r

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UOCUMENT IS THE ~ROPERT'I' OF THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF TtE: INSPECTOR GENERAL IF LOANED TO ANOTH EA AGENCY IT AND ITS COIIITENTS ARE NOT TO BE REPRODUCED OR OISTAIBUTEO OUTSIDE HIE. RECEI\/ING AGENCY WITHOUT OIG'S PEl'IMISSION.

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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DETAILS Memorandum to File

Subject:

r )(7)(C) b As a proactive initiative ...."=""_ __. nd OIG Engineering Intern has followed the unexpected trip at Callaway Nuclear Power Plant on August 11 , 2015, due to a wiring error for the main transformer.

While responding to this trip, the Licensee found that one of the two safety-related, motor-driven auxiliary feedwater flow control valve could not perform its safety function. It was also determined that these control valves have a history of inoperability and have exceeded technical specifications in the past.

OIG learned that NRC completed a "post maintenance inspection" of one of the motor-driven auxiliary feedwater flow control valve in December 2014 and reported no findings.

Below is a summary of documentary information reviewed to date:

Timeline Oct. 2014 - MD 8.3 - Maintenance performed on ALHVOOll. The setting of a valve potentiometer was not verified following maintenance.

October 23, 2014- MD 8.3 -The bridge rectifier was modified on a control card for valve ALHV0007 November 15, 2014 -MD 8.3- The bridge rectifier was modified on a control card for Valve ALHVOOOS.

December 3, 2014- MD 8.3 -Valve ALHVOOOS did not close following a plant trip because the bridge rectifier failed.

December 3, 2014 - MD 8.3 - The licensee replaced the ALHVOOOS Control card with another having a similarly modified bridge rectifier.

December 4, 2014 - NRC inspection 2014005, Included post-maintenance inspection of motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs July 23, 2015 - MD 8.3 -ALHV0011 closed and failed to reopen following a reactor scram.

August 11, 2015- MD 8.3 - Valve ALHV0007 closed following a plant trip but did not open upon demand because the bridge rectifier failed.

THIS DOCUMENT IS nu; P~OPERTV OF THE U.<> NUCLEAR REGULATORY COMMISSION. OFFICE OF THE IN&PECTOR GENERAL (OIGI If LOANED TO ANOTH[;R AGENC, , IT A"IO rrs CONTEHT8 ARE NOT TO BE REPROOuc-c, OP C,ISTRIBUTED OUTSIDE tlc RfCfJVINC AGENCY WIHiOUT OIG'S PEfCMISSION OFFICIAL USE ONL'I-OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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l<C__.l_ _ _ _ ____,1 REVIEW CASE FILE NUMBER 13 027 NRC Office of the Inspector General PAGE 2 OF 4 PAGES August 11, 2015 - MD 8.3 - The control card for ALHV0005 was replaced with a properly modified card.

Sept 19 - NRC special inspection, non-cited violation for declaring the system operable without fully understanding the failure mechanism.

Summary of 2014 Card failure, ALHV000S

- In October and November 2014, two auxiliary feedwater valves were fitted with new control valve control cards. These cards were reverse engineered by a vendor (Nuclear Logistics), from the existing cards. The bridge rectifiers used in the original cards were unavailable due to obsolescence, so new ones were made and used.

- A Plant trip caused valve ALHV0005 (same component type as the 2015 card failure, ALHV0007) to fail, one month after installation of the modified cards. The bridge rectifier was found to be damaged, and the card was determined to have failed due to an "infant mortality issue. The failed card was replaced by an identical card.

- Post-maintenance testing of the replaced card, as well as surveillance testing of both cards until the 2015 plant trip did not expose any failure conditions to the cards.

- NRC inspection 2014005 was conducted and included post-maintenance inspection of motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs. No findings were identified.

- In response to the 2014 card failure, Nuclear Logistics designed new modified bridge rectifiers with increased amperage ratings for the cards, which were installed for both auxiliary feedwater valves, but the ALHV0005 and 0007 cards were allowed to remain in use until the next refueling cycle in 2016.

THIS DOCUMENT IS TH[ PROPERTY OF Tiff U &, NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIGI IF LOANED TO A"10THER AGENCY, II ANO ITS CONTENTS ARE NOT TO BE REPRODUCED OR OISTRIOUTFO OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIGIAIGI Form 724 Revised: December 2014

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<C  :\_ _ _ _ __.I REVIEW CASE FILE NUMBER 13 027 NRC Office of the Inspector General PAGE 3 OF 4 PAGES Summary of 2015 Card Failure, ALHV0007

- On August 11, 2015, a grid disturbance caused a turbine and reactor trip at Callaway plant and initiated Auxiliary Feedwater System actuations. All systems involved in the reactor trip Initially responded as expected. Approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following the trip, while attempting to transfer to the motor-driven auxiliary feedwater pumps, flow control valve ALHV0007, would not respond to "open" demand signals from t he control room.

- The bridge rectifier was again found to be damaged.

- According to the licensee, the operating temperatures affected performance of t he cards, and placed them in unexpected o perating conditions

- New cards from Nuclear Logistics with the increased amperage rating rectifiers were installed for both ALHVO00S and 0007.

- NRC conducted a special inspection on Sept 19, and issued a non-cited violation for declaring the system operable without fully understanding the failure mechanism. A partial systems walkdown was performed, no findings were identified.

NRC Inspection report data:

1. Inspection Report 2014005; P.15, post-maintenance inspection scope

a. December 4, 2014, motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs, Job 14006195. The inspectors reviewed licensing- and design-basis documents for the structures, systems, and components and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, and components. These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 711 11.19.

b. Findings: No findings were identified.

2. Special inspection Report 2015003 Cornerstone: Mitigating Systems. Green.

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CASE FILE "NUMBER 13 027 NRC Office of the Inspector General PAGE 4 OF 4 PAGES The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensee's fai lure to follow their operability determination procedure.

Specifically, when an auxiliary feedwater control valve failed to operate from the main control room, the licensee failed to evaluate the operability of the component in accordance with Procedure ODP-ZZ-00001, Addendum 151 "Operability and Functionality Determinations." The immediate corrective action taken by the licensee was to evaluate the operability of the flow control valve. After determining that t he equipment was inoperable, the licensee entered the required technical specification condition and performed the required technical specification actions. The licensee entered this issue into their corrective action program as Callaway Action Request 201502708.

This performance deficiency is more than minor and, therefore, a finding, because, if left uncorrected, it has the potential to lead to a more significant safety concern if safety-related systems are not properly evaluated for operability. The finding affects the Mitigating System Cornerstone because the performance deficiency is related to the auxiliary feedwater system's ability to conduct short-term decay heat removal.

Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions,"

the finding was determined to be of very low safety significance because it did not affect system design, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equ1ipment designated as high safety-significance. This finding has a cross-cutting aspect of challenge the un.known in the human performance cross-cutting area because the licensee did not stop when faced with uncertain conditions. Specifically, rather than declaring the system inoperable and allowing the process to evaluate the condition, the licensee declared the system operable without fully understanding the failure mechanism [H.11]. (Section 1R15)

Attached Documents:

1. Licensee Event Notification

2. Licensee Event Report (LER), October 1, 2015

3. Licensee Event Report (LER), October 12, 2015 (b)(7)(C)

NAME I SIGNATURE DATE 12/1/2015 Hl:V1t:.vvt:R NAME\ SI NATURE l(b)(7)(C) I DATE THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION. OFFICE OF T11E INSPECTOR GENERAL (OIG).

tF LOANED TO ANOTHER AGENC~, IT AND ITS CONTENTS ARE NOT TO BE RFPRO0UCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

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Case 15 029, IP and Inspection Report Report Date: 08/18/2015 Narrative:

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- l(b)(?)(C) I REVIEW (b)(7)(A)

CASE FILE. NUMBER CASE NRC Office of the Inspector General PAGE 1 OF 1 PAGES DETAILS Memorandum to Fill e Summary of Contact (b)(7)(A),(b )(?)(C)

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(b)(?)(A),(b)(7)( C),(b)(?)(E)

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Case 15 029 Inspection Analysis Report Date: 07/13/2015 Narrative:

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OFFICIAL USE ONLY 1lfemos to File Prepared by: !(b)(7)(C)  ! 08/2412015 Case

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MTF_A-15 07693_St. Lucie Tech Spec_June 2015 Report Date : 06/12/2015 Narrative:

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MTF_Allegation A 15 07693_June 12 2015.docx.dotx.pdf Em Tech Spec 3.5.1(b)_A-15 07693_St. Lucie_ June 2015.pdf LER 2015-001 _Allegation A-15 07693_St. Lucie_ 282 SIT Pipe Leak_Allpdf.pdf l(b)(?)(C) I

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CASE FlLE NUMBER A-15 07693 NRC Office of the Inspector General PAGE 1 OF 2 PAGES I

• oETAILS Objective On May 29, 2015, OIG received an anonymous complaint describing failed NRC oversight by resident inspectors for a safety injection tank pipe leak during the week of April 13, 2015. The alleger believed the plant should have entered technical specification 3.0.3 that requires an accelerated shutdown. Instead, he believes that NRG.allowed for a shutdown at the licensee's convenience. Additionally, the alleger listed NRC staff and NRC positions that he felt were incompetent and inexperienced.

Summary OIG learned that St. Lucie Unit 2 shut down on April 11 2015 due to through wall crack and leak in the 282 safety injection tank (SIT) discharge pipe. Florida Power and Light submitted a License Event Report (LER) on June 1O 2015 describing the event in which they entered technical specification 3.5.1 (b) for an inoperable SIT. Since the location of the leak was non-pressure boundary and the other three safety injection tanks were operable, technical specification 3.0.3, Limiting Conditions for Operation, was not required.

Background/Analysis OIG learned from the Licensee LER that on April 11, 2015, a through wall leak was identified during an investigative walk down of the 12 inch diameter Class 2 piping for the 282 SIT discharge header. Operators declared the SIT inoperable and Technical Specification Limiting Condition of Operation (LCO) 3.5.1 action "b" was entered which requirE;?d the SIT to be restored to Operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or shut down to Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In .accordance with TS and plant procedures, operators subsequently shut down the unit to repair the leak. This condition was determined to be within the plant capability to maintain SIT requirements.

OIG learned from the Licensee's technical specification document there was no need to enter 3.0.3 and the Licensee entered the correct technical specification 3.5.1 action "b".

OIG learned from thel(bJ(7J(CJ I he verified through a search of the licensee's Corrective Action Program (CAP) that during the time the 282 SIT was inoperable; no other SIT were inoperabl.e. l<b\(7Jcc\ I "searched the CAP for the period of March 1 through April 30 using the following equipment tags: SIT 2A1 , SIT 2A2, SIT 281 and SIT 2B2. The only two items that came up were AR 2036424 (March 30, 2015) that identified the lowering 2B2 SIT level trend and AR 2039830 (April 11, 2015) that documented the crack in the 282 SIT discharQe line." l(b)(7)(C) l "also searched the unit 2 control room operator loas for the 1f;ll> OOCUMENT IS TiiE PRO"ERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION. OFFICE OF il1E' INSPECTOR GENEf!JIL 1010 1, IF LOI\N!:0 TO '-NOTHER AGENCY, IT ANO TTS CONT:NTS ARE NOT TO 8E ~PRODUCE;D OR DISTR13UTED OUTSIDE Tlf!, RECEWING AGENCY WITHOUT OIG'S PERMISSION OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI form 724 Revised: December 2014

l_ ,)(_7)_(C_) _ _ _ _ _1 REVIEW (b..,.

CASE FILE NUMBER A-15 07693 NRC Office of the Inspector General PAGE 2 OF 2 PAGES I

same period of time for "3.5.1" which is the Tech Specification for SITs (see attached) to see if they entered an action statement for an inoperable SIT. The only items that came up were related to the 282 SIT."

Recommendation OIG did not develop any evidence that the plant should have entered technical specification 3.0.3 that requires an accelerated shutdown nor the NRC staff were incompetent. Therefore, it is recommended this case be closed to the files of this office.

INAME \SIGNATURE DATE (b)(?){C) June 12, 2015 REVIEWER NAME\ SIGNATURE - /

I

~ /"I (b)(?)(C) 1~S!IOCUMEtfT :s, THE PROPERTY OF THE u.s NUCLEAR R:GULATORY COll'IMISSION. OFFICE OF THf a,s~!:CTOR GeNERA-IOIGl IF I.OAl'l;O TO ,IINOTti!:R AG!;NCr. 11' ANO 11'5 CONTeNTS ARE NOTTO 9£ RE?RODUC!:'O OR OISlRli!IJTEl)

OllTSICE Tt;E RE-CEIVING AG2NCV WITHOUT 01o*s ~!!R~ISS\ON.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG!AIGI i=orm 72~

Revised: December 2014

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.1 SAFETY INJECTION TANKS (SIT)

LIMITING CONDITION FOR OPERATION with:

3.5.1 Each Reactor Coolant System safety injection tank shall be OPERABLE

a. The isolation valve open,

b. A contained borated water volume of between 1420 and 1556 cubic feet,

c. A boron concentration of between 1900 and 2200 ppm of boron, and

d. A nitrogen cover-pressure of between 500 and 650 psig.

APPLICABILITY: MODES 1, 2 and 3*.

ACTIO N:

due to an

a. With one SIT inoperable due to boron concentration not within limits, or or nitrogen cover-p ressure , restore the inability to verify the required water volume inop.erable SIT to OPERABLE status with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwi se, be in at least the HOT STAND BY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

-a,

b. With one SIT inoperable due to reasons other than those stated in ACTION hours; otherwi se, be in restore the inoperable SIT to OPERABLE status *within 24 SHUTD OWN within at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.5.1.1 Each safety injection tank shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by:

1. Verifying that the borated water volume and nitrogen cover-pressure in the tanks are within their limits, and

2. Verifying that each safety injection tank isolation valve is open.

pressurizer pressure is less

• With pressurizer pressure greater than or equal to 1750 psia. When each with a mi"nimum than 1750 psia, at least three safety injection tanks shall be OPERABLE, ed water volume of pressu re of 235 psig and a maximum pressure of 650 psig and a contain n 1900 and 2200 ppm betwee n 1250 and 1556 cubic feet with a boron concentration of betwee have a minimum of boron. With all four safety injection tanks OPERABLE, each tank shall ed water volume of pressu re of 235 psig and a maximum pressure of 650 psig and a contain n 1900 and 2200 ppm of betwee n 833 and 1556 cubic feet with a boron concentration of betwee boron.

3/4 5-1 Amendm ent No. 4-0, Si, 96, 400, ST. LUCIE- UNIT 2 163

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued}

b. At least once per 31 days and once within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase of greater than or equal to 1% of tank volume by verifying the boron concentration of the safety injection tank solution. This latter surveillance is not required when the volume increase makeup source is the RWT and the RWT has not been diluted since Verifying that the RWT boron concentration is equal to or greater than the safety injection tank boron concentration lim.it.

c. At least once per 31 days when the RCS pressure is above 700 psia, by verifying that power to the isolation valve operator is disconnected by maintaining the breaker ope_n by administrative controls.

d. At least once per 18 months by verifying that each safety injection tank isolation valve opens automatically under each of the following conditions:

1. When an actual or simulated RCS pressure signal exceeds 515 psia, and

2. Upon receipt of a safety injection test signal.

ST. LUCIE - UNIT 2 3/4 5-2 Amendment No. ~. 96

June 10, 2015 L-2015-167 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Docwnent Control Desk Washington, D.C. 20555 Re: St. Lucie Unit 2 Docket No. 50-389 Reportable Event: 2015-001 Date of Event: 4/11/2015 Unit 2 Shutdown Due to Through Wall Crack and Leak in the 2B2 Safety Injection Tank Discharne Pipe The attached Licensee Event Report 2015-001 is being submitted pursuant to the requirements of 10 CFR 50.73 to provide notification of the subject event.

Respectfully, Christopher Costanzo Site Vice President St. Lucic Plant CRC/lrb Attachment Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 01/31/2017 02-2014)

,,y*-....,_ Estimated burden per response to comply with this mandatory conedon request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.

• )It

'\, . . ... ~

i LICENSEE EVENT REPORT (LER)

Reported I essons learned are incorporated into the licensing process and fed bad< to lndust,y.

Send c01T111ll8nts regarding burden estimate to tho FOtA, Privacy and lnfoonation Clllections Branch (T-5 F53), U.S. Nuciear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to lnfocollecls.Resource@nrc.gov, and lo the Desk Officer, Office of tnfoonatton and (See Page 2 for required number of RegtAatory AKairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currenUy valid 0MB digits/characters for each block) control rumber, the NRCmay not conduct or sponsor, and a peraon Is net required lo respond to, the infoonation collection.

1. FACILITY NAME 2. DOCKET NUMBER 3. PAGE St. Lucie Unit 2 05000389 1*OF 3

4. TITLE Unit 2 Shutdown Due to Through Wall Crack and Leak in the 2B2 Safety Injection Tank Discharge Pipe

5. EVIENT DATE 6. LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER I REV NO. MONTH DAY YEAR FA.CILITY NAME UVl.,l\o I N U M~ol<

FA.CfllTY NAME DOCKET NUWSER 04 11 2015 2015

• 001

• 00 06 10 2015

9. OPERATING MODE 11 . THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 0 20.2201(b) D 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C) D 50.73(a)(2)(vii) 0 20.2201(d) D 20.2203(a)(3)(ii) 0 50.73(a)(2)(11)(A) 0 50.73(a)(2)(viil)(A) 1 D 20.2203(a)(1) D 20.2203(a)(4) 0 50.73(a)(2)(1i)(B) 0 50.73(a)(2)(viil)(B)

D 20.2203(a)(2)(1) 0 50.36(c)(1 )(l)(A) 0 50.73(a)(2)(1II) D 50.73(a)(2)(ix)(A)

10. POWER LEVEL D 20.2203(a)(2)(11) 0 50.36(c)(1)(ll)(A) D 50.73(a)(2)(1v)(A) D 50.73(a)(2)(x)

D 20.2203(a)(2)(111) 50.36(c)(2) D 50.73(a)(2)(v)(A) D 73.71(a)(4)

D 20.2203(a)(2)(1v) D 50.46(a)(3)(11) D 50.73(a)(2)(v)(B) 73,71(B)(5) 100 D 20.2203(a)(2)(v) l8l 50.73(a)(2)(1)(A) D 50.73(a)(2)(v)(C) 0 OTHER D 20.2203(a)(2)(vi) l8J 50.73(a)(2)(i)(B) 0 50.73(a)(2)(v)(D)

Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER ICENSEE CONTACT !TELEPHONE NUMBER (lnc/ud6 Ives Code)

Lyle R, Berry, Licensing Engineer (772) 467-7680

13. COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT CAUSE SYSTEM COMPONENT MA.NU* REPORTABLE CAUSE SYSTEM COMPONENT MA.NU* REPORTABLE FA.CTURER TOEPIX FACTURER TOEPIX B BQ PSP E065 y

14. SUPPLEMENTAL REPORT EXPECTED 15. EXPECTED MONTH DAY YEAR SUBMISSION 0 YES (If yes, complete 15. EXPECTED SUBMISSION DATE) l8J NO DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 sing/a-spaced typewritten lines)

On 4/11/2015 at 1204 EDT, a through wall leak was identified during an investigative walk down of the 12-inch diameter Class 2 piping for the 2B2 safety injection tank . (SIT) discharge header. Operators declared the SIT inoperable and Technical Specification Limiting Condition of Operation (1,.CO) 3.5.1 action "b" was entered, which required the SIT to be restored to bperable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or shut down to Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In accordance with Technical Specifications (TS) and plant procedures, operators subsequently shut down the unit to repair the leak. The shutdown was uncomplicated and all plant safety systems functioned as designed. The leaking piping was replaced and returned to service on 4/18/2015. A sample of the failed pipe was sent to a metallurgical laboratory for examination. Results of optical and electron microscopic evaluations revealed the cause of failure as low stress high cycle fatigue.

This condition is reportable in accordance with the following requirements: 1) 10 CFR 50.73(a)(2)(i)A, "The completion of a nuclear plant shutdown required by the plant's Technical Specifications," and 2) 10 CFR 50.73(a)(2)(i)(B), "Any operation or condition which was prohibited by the plant's Technical Specifications." This condition was determined not to have a significant impact on the health and safety of the public, since the identified leakage was w~II within the plant capability to maintain SIT requirements and was insignificant as compared to either the SIT discharge flow rate or the safety injection flow rate during design basis events.

NRC FORM 366 (02-2014)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150--0104 EXPIRES: 01/31/2017 02-2014)

/~¥'

Estimated burden per response to comply wilh this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.

Reported lessons learned are incorporated into the licensing process and fed back to lnduslry.

. i Send comments regarding burden estimate to the FOIA. Privacy and Information Ccllections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Wasl'lington, DC 20555-0001, or by

\ .....i LICENSEE EVENT REPORT (LER) internet e-mail to lnfocollecis.Resource@nrc.gov, and to the Desk Officer, Office of Information and Reg~atory Affairs, NEOB-10202, (3150-0104), Office of Mana~nt and Budge~

CONTINUATION SHEET Washington, DC 20503. If a means used to impose an infoonaUon collection does not display a cwently valid 0MB contrcl number, Ille NRC may not conduct or sponsor, and a person is nol required lo respond to, the information collectloo.

1. FACILITY NAME 2. DOCKET 6. LER NUMBER 3. PAGE SEQUENTIAL I REV St. Lucie Unit 2 05000389 YEAR I NUMBER NO.

2 OF 3 2015 001 00 NARRATIVE Description of the Event On 3/30/2015 at approximately 1645 EDT, operator review of Unit 2 control room logs revealed increasing leakage from 2B2 safety injection tank (SIT) (EIIS: BQ, TK) evidenced by increasing depressurization rate and increasing rate of level loss with concurrent increase in rate of Reactor Cavity level rise. After discovery of the increasing SIT leak rate on 3/30/2015, a methodical plan to identify and eliminate the leak was executed and on 4/11/2015 at 1204 EDT, a through wall leak was identified during an investigative walk down of the 12-inch diameter Class 2 piping for the 2B2 SIT discharge header (line l-12"-Sl-459) (EIIS: BQ, PSP) located at an integral attachment weld of a support lug for support Sl-4203-44 (EIIS: BQ, SPT). Operators declared the 2B2 SIT inoperable and Technical Specification Limiting Condition of Operation (LCO) 3.5.1 action "b" was entered, which required the SIT to be restored to Operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or shut down to Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The unit was subsequently shut down to repair the leak. Mode 3 was achieved at 0123 on 4/12/2015. The shutdown was uncomplicated and all plant safety systems functioned as designed. The leaking pipe was replaced and returned to service on 4/18/2015.

Cause of the Event The Root Cause for the piping failure was determined to be a legacy support design which created stress intensification in the piping that is not suitable for the vibration environment.

Analysis of Event A sample of the failed pipe was sent to a metallurgical laboratory for examination. The metallurgical failure analysis confirmed the piping flaw progressed through wall by high cycle fatigue. The only source of loading identified that could produce the number of cycles to failure observed was vibration from the reactor coolant system. Evaluations of the support design revealed that the design of the welded lugs created am elevated local stress intensification that is not suitable for the environment where cyclic loading can occur. While the scope of the investigation did not include measurement of piping displacements from vibration, the evaluations of local stress concentration demonstrated that cyclic loading well below the normal operating loads would be sufficient to exceed the endurance limit for the material which would support the high cycle fatigue.

Safety Significance The safety significance of this event is considered low. The flaw did not prevent the 2B2 safety injection tank from performing its design basis function based on the following considerations.

• The safety injection tank water volume, boron concentration and nitrogen pressure were maintained in accordance with the Technical Specifications.

• The extent of the leakage represents an insignificant fraction of the flow and volume delivered from the safety injection tank in the event of a design basis accident.

• The condition of leakage from the safety tank is continuously monitored by change in safety injection tank level.

NRC FORM 366A (02-2014)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (02-2014) LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME 2. DOCKET 6. LER NUMBER J. PAGE SEQUENTIAL I REV St. Lucie Unit 2 05000389 YEAR I NUMBER NO.

3 OF 3 2015 001 00 NARRATIVE

• In the event of a design basis accident, the safety injection tank performs its function in a relatively short period of time providing limited time for growth of the flaw.

• The SIT tank volume lost during a four hour Station Black Out (SBO) event is insignificant compared to the total volume of the four SIT's.

• In the event of a design basis accident, the safety injection tank pressure will drop reducing the stresses within the piping and the driving force for leakage through the flaw.

• A Probabilistic Risk Analysis (PRA) evaluation was developed with the conservative assumption that 282 SIT was inoperable for about 6 days (i.e., half the time between discovery of unidentified leakage on 3/30/2015 and discovery of 282 SIT leakage on 4/11/2015). The Conditional Core Damage Probability (CCDP) and Conditional Large Early Release Probability (CLERP) values were found to be below the thresholds of 1.0E-06 and 1.0E-07 for CCDP and CL ERP, respectively, as required by RG-1.174 for the risk to be Small.

This condition is reportable in accordance with the following requirements: 1) 10 CFR 50.73(a)(2)(i)A, "The completion of a nuclear plant shutdown required by the plant's Technical Specifications," and 2) 10 CFR 50.73(a)(2)(i)(B), "Any operation or condition which was prohibited by the plant's Technical Specifications."

Corrective Actions The corrective actions listed below are entered into the site corrective action program. Any changes to the actions will be managed under the corrective action program.

1. Engineering Design Change EC 283720 replaced the leaking piping spool piece with the through-wall flaw

{line l-12"-Sl-459) and modified the supports for line Sl-459 and removed support Sl-4203-44. This action was completed 4/18/2015.

2. Revise procedure STD-C-010, Piping and Support Analysis Requirements St. Lucie Units 1 and 2, to include more detail related to welded attachments specifically addressing avoiding extended lugs which develop a bending moment and considerations associated with using welded attachments in an environment which involves cyclic loading. This action is scheduled.

Similar Events A review to identify similar events was performed by searching the condition reports in the plant corrective action data base initiated between March 1, 2010 and May 14, 2015. No previous similar events or causal analyses identifying fatigue failure of large bore piping were identified. A through wall leak of the 2B1 SIT vent valve weld reported in recent St. Lucie Unit 2 LER 2014-001-01 , although in the same system and resulting from high cycle low stress fatigue, occurred on small bore piping due to a failure to comply with work order documents utilized by plant maintenance.

Failed Component Piping Spool Piece 1-12"-Sl-459 is an ASME Class 2, Seismic Class I pipe with a design pressure of 700 psig and a design temperature of 350°F. The 12" pipe was originally made of SA-358, Cl. 1, TP 304 stainless steel with a nominal wall thickness of 0.375" (12" Schedule 40S, Pipe Code SS-3).

Manufacturer Ebasco Services, Inc ((E065)

OFFICIAL USE ONLY Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: iJ Subject!... _1<

(b-l(7 _A_ l _ _ _ _ _ _ _ _ _ _ _ _ _ __,

Report Date: 06/02/2015 Narrative:

Moved to case file

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= )- I Concurred by Name

..... 06/0312015 01 :06 PM Date Status: Open Allow Other Editors: Edit Authorization:

(Management],

(b)(7)(C)

Request Review:

Approval*

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(?)(C) I06/29/1015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: [)

Subject:

MTF_Case 13 042_Flood Report Date: 05/28/2015 Narrative:

moved to case file

,.,,..,.,=,---. Date

!(b)(7)(C)  ! Concurred by Name 06/29/2015 01:43 PM Status: Open Allow Other Editors: Edit Authorization:

Request Review:

Approval:

OFFICIAL USE ONlY 1

OFFICIAL USE ONLY Memos to File Prepared byl(b)(?)(C) I os1191201s Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Dodlnk: ']

Subject:

MTF_Case 14-007_Hardened vents Report Date: 05/19/2015 Narrative:

Moved to case file Concurred by Name Date

,(b"""

)(?""' C ), --,I

)(""' 05/19/2015 08;06 AM Concurred by Neme Date

!(b)(?)(C) I ' 05/19/2015 08:12 AM Status: Open Allow Other Editors: Edit Authorization:

ent RC Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File PrepQred by: j(b)(7)(C) I06/15/2015 Case

Title:

Special Project: NRC Case Number* C 13 027 Regulatory Oversight Origination Doclink: ~

Subject:

MTF_Case 15-025_G:Drive review for contract information ReportDate: 05/15/2015 Narrative:

Moved to case 15 025 Concurred by Name Date

, (b"""

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)(C""'")- - , I 06/15/2015 05: 13 PM f O'lCUrred by Name 06/23/20 15 -f2:38 PM--

Date Status: Open Allow Other Editors: Edit Authorization:

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File Prepared by: !(b)(?)(C) 05/14/2015 Case

Title:

'Special Project: NRC Case Number: C 13 027

Regulatory Oversight I

Subject:

MTF - For Allegation A-15-07666 - Summer ROP summary Report Date: 05/14/2015 Narrative:

.. ~

MTF _NCV and FINDINGS per region and Summer_S years from May 13 2015_May 13 2015.dotx J..

Allegation A-15-07666_Digital City Summary_Summer Station_May 2015.pdf r.oncurred by Name Date 05/14i2015 10:28 AM 1

Status: Closed Allow Other Editors: Edit Authortzalion:

Request Review:

Approval. Approved l(b)(?)(C) 05/18/2015 07;28:11 PM OFFICIAL USE ONLY 1

l(b )(?)(Cl I REVIEW CASE FILE NUMBER 13*027; Allegation A-15-07666 NRC Office of the Inspector General PAGE 1 OF 2 PAGES DETAILS Memorandum to Fmle l(b )(?)(C)

!reviewed the information contained within NRC's "Digital City - Dynamic Web Page," for the five year time period, May 13, 2010 to May 13, 2015, and learned the following:

Region 1 Region 2 Region3 Region 4 NOII-O!~ Violariffl

• 2 NOl!-Cil!III Viobdoo

• Cn,m US l<er,,Ci1!(1 \161aliou

• I N~t.d \"10b!i01

• C!Wll 1131 NO!I-Cl114 v*,o!Jlic,r;

• GrHII m Noe-ClAC! V',o1all~

• K-'A 8 l'lat-CII~ V'tOWiCll *Cnell ll39 lloo-Cktd \'lolllioo- st.n* 31 Noi:-Cieii Viowios

• NIA 14 NOil-Ch~ V'10l.ili011 * ~IA 1,)

NOfioCitee \'lola!f011

• KIA 2&

Nor.-CiUICI \',o!lliOll

• SL-I\" ll ~lt~V-~-TBD I NCt--Ci~ Vicl!li~- SL-I'\' 62 NMA:it~ \1c-!Jli"'1

• R-l\' *1 From the same data source, the number of Findings per region.

Region 1 Region 2 Region 3 Region 4 Fif'.dutj

• Cn,en l':Q F~~ - G1etn 190 Fir.dln.r;

• Ko~-\ 27 Fu-.6!!;-NIA 10 FU!!lit!

• Gas 161 Fmdir;g - Grf!t?l. 118 Fir.dill;

• SL*I\' l FUMM!-SL-1\' 1 Fl£di1~

• NIA 14 Fir.ein_; * 'Whitt 4 Fi!id!r,g-N.l.l 24 Fis:.'!Ulg

• Whitt 3 Futit~

• Whill! 2 From the same data source, the number of Greater than Green Findings (i.e. white, yellow, red):

Region 1 Region 2 Region 3 Region 4

- ~ ",,"iol&tioc * 'Whlllt l 1'lo6lllf*m.ltt Vtol&11oo - Wl>ito u J

\ '!olldOII

• Qad

\"<<>lark>a . _,,,

\'lobilicl,,-Ydlo,r I

),I

~

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Vlolldoc * '1\'11111

.,,-iolatim:-Yelln" l

21 l

.J.pp,P.C<V"'1e!ioo-l\'llm, Pir.dillJ * 'Mlhl VICltt!Odl*Rt>l'DIII...,. .(...-PM,:t:i:1/Vlt ..l/lAl* ~-11.M-4111

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• SC'\'l , ~C~#Wr..tJ'"".,_.

• HP*ll-1-st,,-:.,

• pa.Aflt,a~~-c,,J~~

- 00 *-* * -***- - * * * - - H H Y'- .b&o.

- *--* ,w ....

,.fMC*I Pt'\MiMriN Doclr.t'Scoo>,. Ol(IOOJ~$ IC) o,,21'2010 St.1-!

"..... *SCWE:!< ">IP:N 'PIR:N

( ) p e a : ~ Di&coh.d \!!,l}.UN~

(l'll-!lr...., .. c_s.r,..-c1,w......,.

TIii NKC abo bm dttcramed tblf ltlf:,-.t IDtlri(t:ly eoeod te.tw'() ....... c;OdlliNrlockc~ Ml as \D PfC\*mcJDMt IO *W.-- aat llldw:,rin,d 1<c.n1-tv SG&isa,-..iao f1' JO C8 73..l~ (tXl),

• cud Ilia -'8ntNtltN:1 J\W...

():.Olice).la~-.ibllbe-h'"'kC~~--Nodcitil<ouideft:d~di,ttcm*adi.bcaueiri,-,.,_c-d*b \\'liaitidciq,J'Ot'~Wlw'pgpo,.a.,O..ti,g.,.-c~Oidmd&tdu\'1005000391"!010$.0l.f~to c...is.r..,...--.A....._,.,"-.,.v--1.,*os00019't:01114Cl-o1. r*,ooc-..s.&pr,1<i-,;,-.

From the same data source (NRC Digital City), the number of green findings per year for Summer Station:

2010 2011 2012 2013 2014

I I,.~ ~ I ~ I l f!r.6,,r

• Cne r

Xor..Cir.i ,101moc:

• Cnm \"iol.ldcc. CM. I 1

~....Cl*~ \'lobliJ:c. I!

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• Crtm 9 N"....Cltt<: .,..iolllli<<.

• CneA I (b)(IJ(C)

IN4ME \ SjGNAn JAi= DATE (b)(7 )(C)

May 14, 2015 REVIEWER NAME\ SIGNATURE DATE

/L/ _;p..,_c r I j_.

l(b)(7)(C)

TH!S OOCUMENT !S THE PROPERTY Of THE U.S. NUCLEAR REGULATORY COMMISSION. OFFlc:£ OF THE INSPECTOR G~NERAL (OIG).

1; LOANED TO ANOTH'ER AGE.NC~, IT ANO ITS COHTENTS Af!!; NOT TO 8E REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT Ot~*S PEIRMISSION, OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: Decemoer 2014

OFFICIAL USE ONLY Memos to File Pr*epared by: l(b)(?)(C) I 05/1411015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: CJ

Subject:

MTF - For Allegation A-15-07666, ROP Finding Responsibilites, IMC 0102 Report Date: 05/14/2015 Narrative: .L.. *

' ~-~1 MTF_ROP findings oversight_IMay 2015.docx m::m-.

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Allegation A-15-07666_1MC 0102_Reporting ROP Findings Responsibilities.pdf I

..................--. Concurred by Name l(b)(/)(C) 05/14/2015 10:40 AM Date Status: Closed Allow Other Editors: Edit Authorization :

Request Review:

l(b)(7)(C )

Approval: Approved .__ _ __. 05/1812015 07:28.53 PM OFFICIAL USE ONLY 1

b. . ,1)/7. ._')/. _C)_ _ _ _ ____.1 REVIEW

.lli._

CASE FILE NUMBER 13-027; Allegation A-15-07666 NRC Office of the Inspector General PAGE 1 OF 1 PAGES DETAILS Memorandum to File Review of Regulatory Documents NRC Manual Chapter 0102, "Oversight and Objectivity of Inspectors and Examiners at Reactor Facilities," nrc gov/docs/ML 1201'rv1L 12012A053.pdf , provides the policy for management involvement and oversight of inspections and other on-site inspection related activities at reactor facilities.

The general oversight responsibilities for the Resident lnsp,ectors, Line Managers (i.e. Branch Chiefs), and Division Directors are:

Resident Inspector:

"Ail NRC staff who leads NRC on-site activities should brief the immediate line supervisors responsible for the activity and the SRI regarding their findings before any exit meeting with the facility licensee takes place."

(page 3)

Senior Resident Inspector:

Senior Resident Inspectors should routinely brief their immediate supervisor on resident inspection issues and findings and should keep their supervisor informed of scheduled exit meetings. (page 3)

Line Manager:

Line managers responsible for an on-site activity should discuss the findings and concerns with the employees assigned to the activity before the facility exit meeting is held. Discussions should focus on potential safety and regulatory approaches to issues to ensure mixed messages are not sent to the licensee. (page 4)

Line managers will oversee significance determinations of inspection findings and any enforcement decisions involving facilities or activities for which they are responsible. (page 4)

Division Directors:

Division directors should meet with their subordinate line managers on a regular basis (e.g., weekly) to discuss on-site activities, including significant findings, trends, and potentially generic issyes. Their level of involvement should be proportional to the significance of the findings. They shall ensure that an appropriate NRC manager is present at those on-site activity exit meetings where findings have resulted in an apparent significant finding. (page 5)

(b)(7)(C) NAME\ SIGNATURE May 14, 2015 REVIEWER NAME\ SIGNATURE l(b)(? )(C) I DATE THIS DOCUMENT IS THE PROPERTY OF THE U.!!. NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIG/

tF LO,.NED TO ANO-HEil ,_GENCY, tr "NO ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE 'RECEIVING AGENCY WITHOUT OIG'S PERMISSION OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

l...,

(lb..,1

)(_.7).._ ) _ _ _ _ _ _1

<C....,: REVIEW CASE FILE NUMBER 13-027; Allegation A-15-07666 NRC Office of the Inspector General PAGE 1 OF 1 PAGES DETAILS Memorandum to File Review of Regulatory Documents NRC Manual Chapter 0102, "Oversight and Objectivity of Inspectors and Examiners at Reactor Facilities," [1] provides the policy for management involvement and oversight of inspections and other on-site inspection related activities at reactor facilities.

The general oversight responsibilities for the Resident Inspectors, Line Managers (i.e. Branch Chiefs), and Division Directors are:

Resident Inspector:

"All NRC staff who leads NRC on-site activities should brief the immediate line supervisors responsible for the activity and the SRI regarding their findings before any exit meeting with the facility licensee takes place."

(page 3)

Senior Resident Inspector:

Senior Resident Inspectors should routinely brief their immediate supervisor on resident inspection issues and findings and should keep their supervisor informed of scheduled exit meetings. (page 3)

Line Manager; Line managers responsible for an on-site activity should discuss the findings and concerns with the employees assigned to the activity before the facility exit meeting is held. Discussions should focus on potential safety and regulatory approaches to issues to ensure mixed messages are not sent to the licensee. (page 4)

Line managers will oversee significance determinations of inspection findings and any enforcement decisions involving facilities or activities for which they are responsible. (page 4)

Division Directors; Division directors should meet with their subordinate line managers on a regular basis (e.g., weekly) to discuss on-site activities, including significant findings, trends, and potentially generic issues. Their level of involvement should be proportional to the significance of the findings. They shall ensure that an appropriate NRC manager is present at those on-site activity exit meetings where findings have resulted in an apparent significant finding. (page 5)

(b)(7)(C) INAME \ SIGNATURE I\OJ\t /\l,J REVIEWER NAME \ SIGNATURE I May 14, 2015 DATE (b)(7)(C)

THIS OOCUME~T IS TtiE PROPERTY OF THE U.S. N ~ REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIG IF LOANt:O TO ANOTHER AOENCt, IT ANO ITS CONTENTS ARE NOT TO BE REJ>ROOUCED OR OISTFH9UTEO OUTSIDE l'HE RECEIVING AGENCY WITHOUT OIG' S PERMISSION.

OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

OFFICIAL USE ONLY Me11JIJU!L.File Prepared by: ~ 05/13/1015 Case

Title:

Special Project: NRC Case Number* C 13 027 Regulatory Oversight Origination Dodink: 0

Subject:

MTF for summary of Non-Cited Violations and Findings Report Date: 05/13/2015 Narrative:

lwJ ~

L MTF _NCV and FINDINGS per region_S years from May 13 201 S_r-.t ay 13 2015.dotx MTF_NCV and FINDINGS per reglon_S years from May 13 201 S_May 13 2015.dotx.pdf

..,,..,.,,,,.,.,,,......-.Concurred by Name Date l(b)(7)(C ) I 05/13/201510:1 1 AM Concurred by Name Data Jos!lp_h A. McMillan 05/18/2015 05:68 PM Status: Closed Allow Other Editors: Edit Authorization:

Request Review:

Approval. Approved Joseph A. McMillan 05/18/2015 05:09:00 PM OFFICIAL USE ONLY 1

l(b)/?)(C I REVIEW CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 1 OF 2 PAGES DETAILS Memorandum to File On Tuesdav May 13, 2015, AIGI Joseph McMillian requested a summary of Non-Cited Violations.

{b)C7)(C) !reviewed the information contained within NRC's "Digital City - Dynamic Web Page,"

for the time period, May 13, 2010 to May 13, 2015, and learned the following:

Region 1 Region 2 Region 3 Region 4 KesH:i1td Violl!ior.

• 2 Ncr*.Clt<<! Vio1J1ioo

• Gnc m NCSI-Cil~ Violation -Cl't!!II IHI N'Otl-Cim\'iolJtil'!I- I N'mCu!d \'lolllim

• Glttll 195 Noo-Chtd Vl.o!Jtior.

• NIA a NCOI-Ci1!11 \'lolllliCII

• Gnai 1SJ9 Noo-Cllld Violftlon- SL-I\' 31 NOll-CitllCI Violllim -NIA 14 N!>>C!ted \'loll!IM

• NIA 20 N('l)('.J~ \1oll!im

• NIA 18 Jio,,-(;it..S ViolotlOO - SL-JY ./.I Noo-Ciacl \"iolllloo - TBD 1 11'0&-Cired Violtticn

• SL-IV 62 NO!l,(:Utd \'!olitlea. SU\' Tl From the same data sourcer )(7)(C) f ummarized the number of Findings per region .

Region 1 Region 2 Region 3 Region 4 Fir.dmi

• GrtC liO Findulg

• Gna 190 Fir.ding - NIA li Flnclis:g

• NIA 10 F"Ulding - Gmn 161 Fu.du!~ -Gnc m FioolJlg

• SJ...n' l Findwi:

• SL-1\1 I Fio:ling -NIA 24 Fi:-.ding

• TI'lliu 4 Fa~-?i/A 24 Fum_g - \'\'lint 3 l Fmin~ - Whit!

The following def'initions are contained within Inspection Manual Chapter (IMC) 0612:

Non-Cited Violation (NCV }. - A m ethod for dispositioning a Severity Level IV violation or a violation associated with a fi nding t hat is charact erized as Green (very low safety significance). Provided applicable criteria in the Enforcement Policy are met, such findings are documented as violations, but are not cited in notices of violation, which normally require w ritt en responses from licensees.

Finding. - A performance deficiency of More-than-Minor significance. A finding may or may not result in a violation.

(b)(7)(C)

NAME\ SIGNATURE DATE May 13, 2015 REVIEWER NAME\ SIGNATURE DATE Joseph A. McMillan WIS DOCIJMENt l!I T~E l>ROPERTY OF THE U.S 1'1UCLEAII REGVUTORYCOMMISSION, O~ICc OF THE IN!!PECTOR GENERAL IOIG IF lOANrn TO .\NOTI-IER AGFNrY, ll ANO IT'S CONlENTll ARE HOT TO BE REPROCIUCED Oil DISTRIBUTED OUTSIDE rnr RECEIVING AGENCY WI HOUT l.llG'S PERMISSION.

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

l(b)/?)(C) I REVIEW CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 2 OF 2 PAGES THIS OOCUMEHT IS THE PROPERT'f OF THEUS NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIG)

If LOANED TO ANOTHER AGENCY, IT ANO ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONL\'-OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

l(b)(?)(C) I REVIEW CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 1 OF 2 PAGES DETAILS Memorandum to File On Tuesday ~ay 13, 2015, AIGI Joseph McMillian requested a summary of Non-Cited Violations.

l(bJ(?J(Cl reviewed the information contained within NRC's "Digital City- Dynamic Web Page,"

for the time period, May 13, 2010 to May 13, 2015, and leamed the following:

Region 1 Region 2 Region 3 Region 4

~=~..Citfd \~~*~ .. .2 X~i~ Viob'.i~- Cttim &H

~-OP.t \'iclatioo- GRm 11.31 Noo-Ciet \ iolaio,, - 1 I S~Ci~\*i~ll.d~-Cl'f!tll -~.1 l<l'll-Ci<!4 \ ioutior.

• NIA i N~<l!IIS \iol.ll!Oll

• Gntii 1:;~

-i~-Ci~ \1o1adoo-1't.\ 14 l\*Citt.l \lot.rt<<.* ~*A

~ll<'.-Cltte \iol11i~. S1.,IV 1S 11

)1,!t,Cln6 l.ioUtloo- SL-n* ;s

));.x.-Chte ,~oladat

• TBD I ~ia! VioL'iicll- SU\' 62 N~r~ Viollli~ * ~/.\

N~-C!tt$ \'Joladoe

• SUV 1!*

1 II I

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From the same data source, ~ummarized the number of Findings per region .

Region 1 Region 2 Region 3 Region 4 Fir.~lr.!-GNtll 1- ~ - Grtm ISv Fir.Gif".~ - N.'.-\ J- Fir.d~~

• NiA 10 Flmin~-Crem 161 Ftr.d~* Gtu llS Fir~ls:! - SL-IY l Fir.d~-SL-1\' I f~g-~;A 14 Fir~~! - White 4 F'~ -~IA 24 Fir.6lli~

• W!li!t 3 F!tlli!!J * "hm 2 The following definitions are contained within Inspection Manual Chapter (IMC) 0612:

Non-Cited Violation {NCV}. - A method for dispositioning a Severity Level IV violation or a vlolatlon associated with a finding that is characterized as Green (very low safety significance). Provided applicable criteria in the Enforcement Policy are met, such findings are documented as violations, but are not cited in notices of violation, which normally require written responses from licensees.

Finding. - A performance deficiency of More-than-Minor significance. A finding may or may not result in a violation.

(b)(f)(C) INAME\ SIGNATURE DATE (b)(7)(C) May 13, 2015 I

J-t 7 /1S--

- * ,_, *-* NAM!: I .:>>!">NI'\ I UKJ:

Joseph A. McMillan C. ~-.. - ~:::........ ....~:--*-::..*.

Tt<IS DOCUMENTIS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY Co'-'MISSION, OFFICE OF THE INSPECTOR GENERAL OIGI-IF LOANED TO ANOTHER AGENCY. IT AND ITS CONTENTS ARE NOT TO BE REPRODIJCEO OR DISTRIB(/TED OUTSIDE THE RECEIVING .AGENCY WITHOu r OIG'S PERhUSSIOtj, OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION OIG/AIGt Form 724 Revised: December 2014

OFFICIAL USE ONLY Memos to File Prepared by; l(b)(7)(C ) I05107(2015 Case

Title:

Special Project: NRG Case Number: C 13 027 Regulatory Oversight Origination Doclink: 0

Subject:

MTF SONGS Lessons Learned and OIG Event Inquiry Report Date: 05/07/2015 Narrative:

~.1

~I MTF_SONGS Lessons Learned Memo and O IG Report Findings_May 2015.dotx Ell

• J..

MTF_SONGS Lessons Learned Memo and OIG Report Findings_May 2015.pdf l(b)(7)(C) I

.......,.....,,......--.Concurred by Name 05/07/2015 03:04 PM Date Concurred by Name Date

~Jos~ph A. ~cMillan 05/12/201 5 08:13 AM Status: Open Allow Other Editors : Edit Authorization :

Request Review:

Approval.

OFFICIAL USE ONLY 1

l.(b

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CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 1 OF 4 PAGES DETAILS Memorandum to File BACKGROUND:

On March 6, 2015, the NRC staff docketed a memorandum titled, "REVIEW OF LESSONS LEARNED FROM THE SAN ONOFRE STEAM GENERATOR TUBE DEGRADATION EVENT" that provided a comprehensive review of lessons learned from the San Onofre Nuclear Generating Station (SONGS) steam generator tube degradation event and provided a summary of actions [ADAMS Accession No. ML15062A125.) As directed by the tasking memorandum dated March 20, 2014 [ADAMS Accession No. ML14028A028], NRC staff evaluated the agency's response to the event under eight topics to identify enhancements to NRC processes and programs that could improve agency response to similar technically complex, highly visible events in the future. Ultimately, the staff identified 17 actions across eight topics. The st aff included in this review, the OIG event inquiry titled, "Office of the Inspector General (OIG) Event Inquiry OIG-13-006, "NRC Oversight of Licensee's Use of 10 CFR 50.59 Process to Replace SONG'S Steam Generators," October 7, 2014,

[ADAMS Accession No. ML14276A478.]"

RESULTS:

The issues and findings identified within the OIG event inquiry had considerable significance in the staff's actions.

Specifically, the findings within the OIG event inquiry report were addressed in 7 out of the 17 actions and are:

1. The staff is developing a regulatory issue summary (RIS) to inform licensees of a potentially misleading statement in the NRC-endorsed 10 CFR 50.59 guidance contained in NEI 96-07, Revision 1.

2. Staff will develop a second RIS to highlight important aspects of the 10 CFR 50.59 guidance related to shortcomings identified in the 10 CFR 50.59 screening and evaluation process for the replacement steam generators at SONGS.

3. The NRC staff is also revising regulatory guide (RG) 1.187 to add an exception to the NRC's endorsement of NEI 96-07, Revision 1, related to the potentially misleading statement.

4. The staff is conducting workshops with NRC regional and headquarters employees to enhance their understanding of the 10 CFR 50.59 process, and will develop formal initial and continuing training on the 10 CFR 50.59 process.

5. The staff is also considering an update to the inspection procedures governing inspectors' performance of 10 CFR 50.59 inspections, as well as inspections related to steam generator replacements and other major plant modifications to appropriately focus inspection reviews.

6. The staff will review and revise, as necessary, internal procedures providing guidance and direction for licensing p roject managers (PM) to clarify the scope, depth, frequency, and timeliness requirements for licensing PM reviews of documented 10 CFR 50.59 evaluation 17 Topic 1 summaries included in licensee submittals pursuant to 10 CFR S0.71(e) and 10 CFR S0.59(d)(2).

7. The staff is developing general guidance to assist licensees, as well as the NRC licensing and inspection staff, in determining whether steam generators necessitate a detailed review. These reviews may be performed as part of a construction permit or operating license application, design certification or combined license application, a steam generator modification or replacement, or a request for licensing action related to steam generators that THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF THE IN~PECTOR GENERAL (OIG) 1r lOANEO TO ANOTHER AGENC~, IT AND ITS CONTENT5 AIIE NOT TO BE llEPROOUCf'O 011 DlrRIBUTE0 OUT! ,or WE RECEIVING AGENCY WITHOUT OIG'S PERMISSION OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

ll(b..... 7).._

1)(....  :) _ _ _ ___.1 REVIEW (C...

CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 2 OF 4 PAGES may be operated under different operating conditions, such as for a power uprate.

However, one of the findings documented in the OIG event inquiry stated that "without reviewing additional information concerning the evaluation conclusions, there is no assurance that NRC reached the correct conclusion in its 2009 inspection that SONGS did not*need a license amendment for its steam generator replacement." This finding was not included in the SONG's learned tasking memorandum. As noted in the OIG event inquiry, Friends of the Earth was awaiting an answer to their filed 2.206 petition which requested an answer to this question. Ultimately, the staff rendered the 2.206 petition as " moot by the closure of the reactors at SONGS.

ANALYSIS:

The staff's lessons learned memorandum summarized the three issues in the OIG report as the following:

1. There were missed opportunities during the NRC Region IV 2009 inspection to identify weaknesses in the SONGS steam generator 10 CFR 50.59 screening and evaluation package.

2. The 2012 Augmented Inspection Team (AIT) review of SCE's 10 CFR 50.59 evaluation did not document the answer to the question of whether a license amendment was required.

3. The NRC did not consistently apply oversight to the San Onofre updated final safety analysis report (UFSAR) following biennial UFSAR submittals.

For the first issue, the staff determined that the following statement from NEI 96-07, Revision 1, provides potentially misleading guidance:

By way of contrast, the following changes are not considered departures from a method of evaluation described in the UFSAR: Use of a methodology revision that is documented as providing results that are essentially the same as, or more conservative than, either the previous revision of the same methodology or another methodology previously accepted by NRC through issuance of an SER [safety evaluation report].

The NRC staff determined that this sentence from NEI 96-07, Revision 1, does not accurately reflect the definition in 10 CFR 50.59(a)(2) in that:

• It could be read to infer that "methodology revision" results could be compared to "the previous revision of the same methodology" instead of being compared to the revision currently specified in the FSAR which may be an earlier revision than the "previous revision;" and

• It could be r,ead to infer that " m ethodology revision" results could be compared t o "another methodology previously accepted by NRC through issuance of an SER" instead of being compared to the methodology currently specified in the FSAR.

To respond to this concern, the staff proposed the first RIS and a revision to RG 1.187 to address guida,nce in NEI 96-07, Revision 1, related to 10 CFR 50.59(c)(2), criterion viii.

Additionally for the first issue, the staff had identified a second RIS which will also highlight important aspects of the Tfll(; OOCUMENT IS THf PROPERf OF THE U.S. NUr:1..:AR REGULATORY COM,..ISSION, O~FICE OF TtiE INSPECTOR GENERAL (011:1 IF lO~EO 10 ANOTHtR AGENC\', IT ANO ITS i:0"'1TNT8 ~R~ NOT TO BE REPROOUCtO OR CIISTRIBUT..D QUTSIOE TH: RECEIYING *GE,._ ~ WIIHf UT OIG"S PERMISSION OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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<C....,l_ _ _ _ __,1 REVIEW CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 3 OF 4 PAGES guidance in NEI 96-07, Revision 1, related to observations identified during the NRC inspection of the San Onofre 10 CFR 50.59 screening and evaluation for the replacement steam generators. These observations were included in the OIG event inquiry and include the following:

• NRC inspectors identified a minor violation of 10 CFR S0.59{d) for an inadequate 10 CFR 50.59 written evaluation for the San Onofre replacement steam generators related to whether the change from one computer code to another {ANSYS to ABAQUS) constituted a departure from the method of evaluation. The NRC inspection report stated that the licensee inappropriately evaluated this change against 10 CFR 50.59(a)(2)(i) (i.e., as a change to an element of a method) rather than against 10 CFR S0.59(a)(2)(ii) (as a change from one method to another method). As such, the licensee's 10 CFR 50.59 evaluation did not address 10 CFR 50.59(a)(2)(ii) for changing to another method by describing whether "that method [ABAQUS] has been approved by NRC for the intended application" [emphasis added]. The OIG event inquiry discusses varying views among NRC staff as to whether the licensee was correct in its evaluation of the change from ANSYS to ABAQUS against 10 CFR 50.59(a){2)(i) as a change to an element of a method. The 10 CFR 50.59 subject matter experts referenced in the OIG event inquiry agree that there was, in fact, a violation. As noted in the inspection report, this violation was dispositioned in accordance with the NRC's enforcement policy as a minor violation, as "there was no reasonable li kelihood that t:he change would ever require NRC approval." The RIS will summarize this issue and ensure a clear documentation of the NRC's regulatory position on this matter.

• The OIG event inquiry stated that the closure of an unresolved item from the AIT report involved a change from a computer program to manual calculations. The RIS will clarify the NRC position that a manual! calculation, no matter how simple, is considered a method of evaluation that in select cases is subject to evaluation under criterion 10 CFR 50.59(c)(2)(viii) .

• The OIG event inquiry stated that at least 14 methods of evaluation listed in Section 3.9 of the San Onofre UFSAR, "Mechanical Systems and Component s," were changed as a result of the st eam generator replacement but were not mentioned in the 10 CFR 50.59 screening. The OIG event inquiry further states that, because of this, the San Onofre 10 CFR 50.59 evaluation did not discuss whether these changes in the method of evaluation meet the definition in 10 CFR 50.59(a)(2) of a departure from the method ofevaluation that would require a license amendment. The RIS will describe t he importance of addressing each applicable change in the UFSAR in the 10 CFR 50.59 screening.

Another discussion in the OIG event inquiry addressed by the staff was the need to conduct workshops and training with regional and headquarters staff, and provide additional continual training opportunities to ensure proper understanding of the 10 CFR 50.59 process. The staff is also evaluating possible updates to the inspection procedu res related to the 10 CFR 50.59 process, including inspection procedures (IP) for the inspection of steam generator replacements and other major plant modifications. Most NRC inspections of licensee 10 CFR 50.59 screenings and evaluations occur under IP 71111.17T and IP 71111.21. These inspection procedures direct inspectors to review licensee implementation of the 10 CFR 50.59 process using the _guidance in NEI 96-07, Revision 1, and as such, the above-described RIS will benefit NRC inspectors as well as licensees. To ensure that inspectors are prepared to effectively carry out their inspection activities, the NRC will be providing ongoing training on the 10 CFR 50.59 screening and evaluation process to its inspectors.

1HIS IJOCUMENT IS THE PROPERTY OF THE U.S NUCLEAR REGULATORY COMMISSION, OFFICE OF WE INSPECTOR GENERAL (OIG, IF LOANro TO ANOTHER AGENCY, IT ANO ns CON THI IS ARE NOT 10 Bf Rf.PROOUCfD OR Dl~fRUIUTEI)

OUTSIOl THE IIECE!VING AGE.Nev WITHOU1 OIG'S PERMISSION OFFICIAL USE ONP/ - OIG INVESTIGATION INFORMATION OIG/AIGI Fo1TT1 724 R&vised: December 2014

ll(b..... (C_ _ _ _ _ _ _I REVIEW 7)....

1)(.....

CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 4 OF 4 PAGES For the second OIG event inquiry issue summarized by the staff in the lesson's learned memorandum, the staff noted that "the 2012 AIT review considered many issues, among which was whether or not the licensee correctly concluded that a license amendment was not required. The AIT and its follow-up inspections reviewed the licensee's 10 CFR 50.59 evaluations related to replacing the steam generators and determined that the licensee' s conclusion that no license amendment was required was consistent with the requirements of 10 CFR 50.59."

For the third issue, the staff's lessons learned memorandum determined that it needs to revise some internal processes to more clearly reflect the scope, depth, frequency, and timeliness expectations for the staff's review of lfcensee submittals required under 10 CFR 50.59 and 10 CFR 50.71 which is titled, "Maintenance of Records, Making of Reports_;,

To address this OIG finding, "the NRC staff has chartered a working group to provide comprehensive staff guidance for completing the 10 CFR 50.71(e) and 10 CFR 50.59(d)(2} reviews" and will update the relevant NRC procedures to include this guidance and provide applicable training.

• Additionally, the staff determined during the evaluation of the licensee' s UFSAR that there was a lack of detail concerning the design characteristics, functions, and acceptance criteria of the various components within the San Onofre steam generators. An identified action in the memorandum is to develop technical review guidance for "Steam Generator Technical Review." Although the primary purpose is for technical review of the steam generators, this guidance will include a section to ensure that licensees have made the appropriate changes to the UFSAR to reflect the replacement steam generator design. The review guidance to be developed for NRC review of 10 CFR S0.71(e) submittals will provide further assurance t hat the UFSAR has the appropriate level of detail."

RECOMMENDATION:

OIG audits schedule an audit in approximately 2 years to determine if the actions from the "REVIEW OF LESSONS LEARNED FROM THE SAN ONOFRE STEAM GENERATOR TUBE DEGRADATION EVENT" were implemented.

(b)(7)(C) NAME I SIGNATURE DATE May 7, 2015 REVIEWER NAME I SIGNATURE DATE Joseph A. McMillan 1111, utlCUMEIH IS 1HE fKOPElll"f Of THE lJ,S NIJl:LEAR REGULATORY COM,..ISSION, C,Fflt:E llf rnr IN~PEG1Clll r.EN£'1** \Olla, II L ;lf,N~O TO ANOTIER *c.uu:v IT "NP ll'J COl4Ti:NT8 ARE NOT Tl) BF ~[MOOUCED OP OIITRIBUTro U lt,r lHl R[C IVIN1; AC<l.NCYWllll(llll 1G'll PE:i<,..18~10N OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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)_ _ _ _ _....,1 REVIEW CASE FllE NUMBER 13-027 NRC Office of the Inspector General PAGE 1 OF 4 PAGES DETAILS Memorandum to File BACKGROUND:

On March 6, 2015, the NRC staff docketed a memorandum titled, "REVIEW OF LESSONS LEARNED FROM THE SAN ONOFRE STEAM GENERATOR TUBE DEGRADATION EVENT" that provided a comprehensive review of lessons learned from the San Onofre Nuclear Generating Station (SONGS) st eam generator tube degradation event and provided a summa ry of actions [ADAMS Accession No. ML15062A125.) As directed by the tasking memorandum dated March 20, 2014 [ADAMS Accession No. ML14028A028], NRC staff evaluated the agency's response to the event under eight topics to identify enhancements to NRC processes and programs that could improve agency response to similar technically complex, highly visible events in the future. Ultimately, the staff identified 17 actions across eight topics. The staff included in this review, the OIG event inquiry titled, "Office of the Inspector General (OIG) Event Inquiry OIG-13-006, "NRC Oversight of Licensee's Use of 10 CFR 50.59 Process to Replace SONG'S Steam Generators," October 7, 2014,

[ADAMS Accession No. ML14276A478.]"

RESULTS:

The issues and findings identified within the OIG event inquiry had considerable significance in-*the staff's actions.

Specifically, the findings within.the OIG event inquiry report were addressed in 7 out of the 17 actions and are:

1. The staff is developing a regulatory issue summary (RIS) to inform licensees of a potentially misleading statement in the NRC-endorsed 10 CFR 50.59 guidance contained in NEI 96-07, Revision 1.

2. Staff will develop a second RIS to highlight important aspects of the 10 CFR 50.59 guidance related to shortcomings identified in the 10 CFR 50.59 screening and evaluation process for the replacement steam generators at SONGS.

3. The NRC staff Is also revising regulatory guide (RG) 1.187 to add an exception to the NRC's endorsement of NEI 96-07, Revision 1, related to the potentially misleading statement.

4. The staff is conducting workshops with NRC regional and headquarters employees to enhance their understanding of the 10 CFR 50.59 process, and will develop formal initial and continuing training on the 10 CFR 50.59 process.

5. The staff is also considering an update to the inspection procedures governing inspectors' performance of 10 CFR 50.59 inspections, as well as inspections related to steam generator replacements and other major plant modifications to appropriately focus inspection reviews.

6. The staff will review and revise, as necessary, internal procedures providing guidance a~d direction for licensing project managers (PM) to clarify the scope, depth, frequency, and timeliness requirements for licensing PM reviews of documented 10 CFR 50.59 evaluation 17 Topic 1 summaries included in licensee submittals pursuant to 10 CFR 50.71(e) and 10 CFR S0.59(d)(2).

7. The staff is developing general guidance to assist licensees, as well as the NRC licensing and inspection staff, in determining whether steam generators necessitate a detailed review. These reviews may be performed as part of a construction permit or operating license_application, design certification or combined license application, a steam generator modification or replacement, or a request for licensing action related to steam generators that THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION. OFFlCE OF THE INSPECTOR GENERAL (OIG).

IF LOANED TO ANOTHER AGENCY, IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG' S PERMISSION.

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Fonn 724 Revised: December 2014

l...,

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CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 2 OF 4 PAGES may be operated under different operating conditions, such as for a power uprate.

However, one of the findings documented in the OIG event inquiry stated that "without reviewing additional information concerning the evaluation conclusions, there is no assurance that NRC reached the correct conclusion in its 2009 inspection that SONGS did not need a license amendment for its steam generator replacement." This finding was not included in the SONG's learned tasking memorandum. As noted in the OIG event inquiry, Friends of the Earth '-'<as awaiting an answer to their filed 2.206 petition which requested an answer to this question. Ultimately, the staff rendered the 2.206 petition as "moot" QY the closure of the reactors at SONGS.

ANALYSIS:

The staffs lessons learned memorandum summarized the three issues in the OIG report as the following:

1. There were missed opportunities during the NRC Region IV 2009 inspection to identify wea.knesses in the SONGS steam generator 10 CFR 50.59 screening and evaluation package.

2. The 2012 Augmented Inspection Team (AIT) review of SCE's 10 CFR 50.59 evah,1ation did not document the answer to the question of whether a license amendment was required.

3. The NRC did not consistently apply oversight to the San Onofre updated final safety analysis report (UFSAR) following biennial UFSAR submittals.

For the first issue, the staff determined that the following statement from NEI 96-07, Revision 1, provides potentially misleading guidance:

By way of contrast, the following changes are not considered departures from a method of evaluation described in the UFSAR: Use of a methodology revision that is documented as providing results that are essentially the same as, or more conservative than, either the prfi!vious revision of the same methodology or another methodology previously accepted by NRC through issuance of an SER [safety evaluation report].

The NRC staff determined that this sentence from NEI 96-07, Revision 1, does not accurately reflect the definition in 10 CFR S0.59(a)(2) in that:

• It could be read to infer that "methodology revision" results could be compared to "the *previous revision of the same methodology" instead of being compared to the revision currently specified in the FSAR which may be an earlier revision than the "previous revision;" and

• It could be read to infer that "methodology revision" results could be compared to "another methodology previously accepted by NRC through issuance of an SER" instead of being compared to the methodology currently specified in the FSAR.

To respond to this concern, the staff proposed the first RIS and. a revision to RG 1.187 to address guidance in NEI 96-07, Revision 1, related to 10 CFR S0.59(c)(2}, criterion viii.

Additionally for the first issue, the staff had identified a second RIS which will also highlight important aspects of the THIS DOCUMENT* IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSLON, OFFICE OF THE INSPECTOR GENERAL (OIG).

IF LOANED TO ANOTHER AG~NCY, IT ANO ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OU TSIDE THE RECEIVING AGENCY WITHOUT OIG' S PERMISSION.

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

ll <b "1)(

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_. REVIEW CASE FILE NUMBER 13-027 N RC Office of the Inspector General PAGE 3 OF 4 PAGES guidance in NEI 96-07, Revision 1, related to observations identified during the NRC inspection of the San Onofre 10 CFR 50.59 screening and evaluation for the replacement steam generators. These observations were included in the OIG event inquiry and include the following:

• NRC inspectors identified a minor violation of 10 CFR 50.59(d) for an inadequate 10 CFR 50.59 written evaluation for the San Onofre replacement steam generators related to whether the change from one computer code to another (ANSYS to ABAQUS) constituted a departure from t he method of evaluation. The NRC inspection report stated that the licensee inappropriately evaluated this change against 10 CFR 50.59(a)(2)(i) (i.e., as a change to an element of a method) rather than against 10 *cFR 50.59(a)(2)(ii) (as a change from one method to another method). As such, the licensee's 10 CFR 50.59 evaluation did not address 10 CFR 50.59(a)(2)(ii) for changing to another method by describing whether "that method [ABAQUS] has been approved by NRC for the intended application" [emphasis added]. The OIG event inquiry discusses varying views among NRC staff as to whether the licensee was correct in its evaluation of the change from ANSYS to ABAQUS against 10 CFR 50.59(a)(2)(i) as a change to an element of a method. The 10 CFR 50.59 subject matter experts referenced in the OIG event inquiry agree that there was, in fact, a violation. As noted in the inspection report, this violation was dispositi~ned in accordance with the NRC's enforcement policy as a minor violation, as "there was no reasonable likelihood that the change would ever require NRC approval." The RIS will summarize this issue and ensure a clear documentation of the NRC's regulatory position on this matter.

• The OIG event inquiry stated that the closure of an unresolved item from the AIT report involved a change from a computer program to manual calculations. The RIS will clarify the NRC position that a manual calculation, no matter how simple, is considered a method of evaluation that in select cases is subject to evaluation under criterion 10 CFR 50.59(c)(2)(viii).

• The OIG event inquiry stated that at least 14 methods of evaluation listed in Section 3.9 of the San Onofre UFSAR, "Mechanical Systems and Components," were changed as a result of the steam generator replacement but were not mentioned in the 10 CFR 50.59 screening. The OIG event inquiry further states that, because of this, the San Onofre 10 CFR 50.59 evaluation did not discuss whether these changes in the method of evaluation meet the definition in 10 CFR 50.S9(a)(2) of a departure from the method ofevaluation that would require a license amendment. The RIS will describe the importance of addressing each applicable change in the UFSAR in the 10 CFR 50.59 screening.

Another discussion in the OIG event inqui ry addressed by the staff was the need to conduct workshops -a nd training with regional and headquarters staff, and provide additional continual training opportunities to ensure proper understanding of the 10 CFR 50.59 process. The staff is also evaluating possible updates to the inspection procedures related to the 10 CFR 50.59 process, including inspection procedures (IP) for the inspection of steam generator replacements and other major plant modifications. Most NRC inspections of licensee 10 CFR 50.59 screenings and evaluations occur under IP 71111.17T and IP 71111.21. These inspection procedures direct inspectors to review licensee implementation of the 10 CFR 50.59 process using the guidance in NEI 96-07, Revision 1, and as such, the above-described RIS wil) benefit NRC inspectors as well as licensees. To ensure that inspectors are prepared to effectively carry out their inspection activities, the NRC .will be providing ongoing training on the 10 CFR 50.59 screening and evaluation process to its inspectors.

THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION. OFFICE OF THE INSPECTOR GENERAL (010).

IF LOANED TO ANOTHER AGENCY, IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AJGI Form 724 Revised: December 2014

l.._ lC_.

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1

? l.._ :1 _ _ _ _____,I REVIEW (C.._

CASE FILE NUMBER 13-027 NRG Office of the Inspector General PAGE 4 OF 4 PAGES For the second OIG event inquiry issue summarized by the staff in the lesson's learned memorandum, the staff noted that "the 2012 AIT review considered many issues, among which was whether or not the licensee correctly concluded that a license amendment was not required. The .AIT and Its follow-up inspections reviewed the licensee's 10 CFR 50.59 evaluations related to replacing the steam generators and determined that the licensee's conclusion that no license amendment was required was consistent with the requirements of 10 CFR 50.59."

For the third Issue, the staffs lessons learned memorandum determined that it needs to revise some internal processes to more clearly reflect the scope, depth, frequency, and timeliness expectations for the staff's review of licensee submittals required under 10 CFR 50.59 and 10 CFR 50.71 which is titled, "Maintenance of Records, Making of Reports."

To address this OIG finding, " t he NRC staff has chartered a working group to provide comprehensive staff guidance for completing the 10 CFR 50.7l(e) and 10 CFR 50.59(d)(2) reviews" and will update t he relevant NRC procedures to include this guidance and provide applicable training.

Additionally, the staff determined during the evaluation of the licensee's UFSAR that there was a lack of detail concerning the design characteristics, functions, and acceptance criteria of the various components within the San Onofre steam generators. An identified action in t he memorandum is to develop technical review guidance for "Steam Generator Technical Review." Although the primary purpose is for technical review of the steam generators, this guidance will include a section to ensure that licensees have made the appropriate changes to the UFSAR to reflect the replacement steam generator design. The review guidance to be developed for NRC review of 10 CFR S0.71(e) submittals will provide further assurance that the UFSAR has the appropriate level of detail."

RECOMMENDATION:

OIG audits schedule an audit in approximately 2 years to determine if the actions from the "REVIEW OF LESSONS LEARNED FROM THE SAN ONOFRE STEAM GENERATOR TUBE DEGRADATION EVENT" were implemented.

(b)(?)(C) .,..,..,. ==-i;;.---------,-;:D:-:A-:T:::-E------------ - - - - - - - - 1i,

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1

\ll)U )\I.,)

May 7, 2015 REVIEWER NAME\ ~~GN~

Joseph A. McMili3IL__--... _ ~{k-' .L!f:=============-

~

THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION. OFFICE OF THE INSPECTOR GENERAL (OIG):

IF LOANED TO ANOTHER AGENCY, 1r ANO irs CONTENTS ARE NOT TO BE REPROOUCED OR DISTRIBUTED OUTSIDE THE F:ECEIVING AGENCY WITHOUT OIG'S PEJ!l~ISSION.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Fenn 724 Revised: December 2014

OFFICIA L USE ONLY Memos to File Prepared by: l(b)(7)(C) 06/30/20/5 1

Case

Title:

Special Project: NRC Case Number: C 13 027

• Regulatory Oversight Origination Doclink': l j (b)( )

7

Subject:

MTF_OIG Strat Plan (D) vs ROP Analysis Report Date: 04/14/2015 Narrative:

E:111 ~

)....

MTF_Strat Plan_2015_Analysis of ROP column 3_ 4 plants vs (D)

~II MTF_Strat Plan_2015_Analysis of ROP column 3_4 plants vs Reports.dotx

- (7) 1-1 tG Strat Plan ROPvm) b2013 and 20 14 March 2015.xlsx D

I

..,,.,.,,....,.,,-----,concurred by Name l(b)(?)(C) 06/30/2015 04:59 PM Dale Status: Open Allow Other editors: Edit Authorization:

Request Review:

Approval:

OFFICIAL USE ONLY 1

TECHNICAL ADVISOR REVIEW CASE FILE NUMBER CASE 13-027 NRG Office of the Inspector General PAGE 1 OF 2 PAGES I

DETAILS Memorandum to File BACKGROUND:

r b)(7)(D)

I RESULTS:

(b)(7)(0 )

ANAYSIS:

(b )(7)(0 )

(b)(7)(0 )

lo.e. David LOCHBAUM) l(b)(?)(O)

(b)(7)(0 )

ftllS t:OCI/MEN: IS THE Pl!'OPERTV Cf , .. E IJ.S, NUCI..EA.11 PfGUI.ATOR~ COMl,USSIO~. OF~tce 0~ THE INSPECTOR GENER4. (OIG).

IF lO.O.NEO TO ~HEil 41\0ENCT, IT ANO *TS CONTENfS 4RE NOT TO BE RfiPRODUCED OR DISTRIBUTED OUTS11lE fHE RECEIVING AGENCY WITHOUT OIG 'S PES!IJ.ISSION.

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION OIG/AIGl Form 724 Revised: December 2014

l(b )(?)(C) l REVIEW CASE FILE NUMBER CASE 13*027 NRC Office of the Inspector General PAGE 2 OF 2 PAGES I

RECOMMENDATION:

(b)(?)(D)

(b)(l)(C)

April 14, 2015 J o ~ illan v .

~ t/~()/lf THIS DOCUMENT IS THE PROPERTY OF Tl1E U.S. NUCLEAR REGUI..ATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIG J, IF LOANED TO ANOTHER AGENCY, IT AND ITS CONTENTS ARE NOT TO BE Ri:PROOUCED OR DISTRIBUTED OUTSIDE TH&. RiCEIVING AGENCY WITHOlfT OlG*s PE~MISSION.

OFFICIAL USE ONL"f- OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

l(b)(7)(C) I REVIEW CASE FILE NUMBER CASE 13-027 NRG Office of the Inspector General PAGE 1 OF 2 PAGES I

DETAILS Memorandum to File BACKGROUND:

r b)(7)(D)

I RESULTS:

(b)(7)(0)

ANAYSIS:

(b)(7)(0 )

(b)(7)(D) h"" n q,1ir11 n r.1-1AAI IM\ l(b)(7)(D)

(b)(7)(0 )

nilS OOCUMENT IS TIIE PROPERTY OF T~E U,S NUCLEAR REGULATORY C0t.lM15310N, OFFICE Of Tf4E INSPECTOR GENERAL IOJC.

IF LOANED TO ANO'ntER AGENC~, 1T AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WIT110UT OIG'S PERMISSION OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

l(b)(7)(C) I REVIEW CASE FILE NUMBER CASE 13-027 NRC Office of the Inspector General PAGE 2 OF 2 PAGES I

RECOMMENDATION:

(b )(7)(0)

IM(7l1~l I April 14, 2015 Joseph McMillan THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIG).

IF LOANED TO ANOTHER AGE NC~. IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBU ED OUTSIDC: THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIGIAIGI Form 724 Revised: December 2014

(b)(4), (b)(7)(D)

OFFICIAL USE ONLY 1lfemos to File Prepared by: l(b)(?)(C) I 03/24/2015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: Cl

Subject:

Review of Palisades ROI - for case 12-056 Report Date: 03/24/2015 Narrative:

Moved to case file Concurred by Name Date 03/26/2015 08:14 AM Starus: Open Allow Other Editors:

Request Review:

Approval.

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(7)(C) I 12/23/2014 1

Case

Title:

Special Project: NRC Case Number

• C 13 027 Regulatory Oversight Origination Doclink:

~

I -

MTF_St Lucie_MSIV Fallure_Dec 23 2014.docx.dotx

Subject:

St. Lucie Main Steam Isolation Valve Event Report Date: 01 /12/2015 Narrative:

Review of the this event is a proactive initiative as described in the 2015 OIG Annual Plan.

cannot find the memo to file, it is not attached and I did not see it in Magnum.

I believe the MTF is attached now.

~ I have reviewed the memo. Please place memo in magnum as a new complaint so that it

~ assigned. The memo indicates a good area for inquiry, which should consider: 1) Aside f rom the automatic reactor trip , what if any consequence or impact did this event have on public health and safety; and 2) the extent to which the staff typically valid design changes during CDBI. q <b)(l)(C) r I15/15)/

Concurred by Name Date

""j

/b'"" c...\ -jj Ji""o/\1. . 12/23/201 41 2:01 PM Concurred by Name Date l..,,..

(b.,..,.

)(7,,..,.

)(C =)-----,1 01/15/2015 11:06 AM Status: Closed AlloW Other Editors: Edit Authorization:

Reques1 Review:

Approval OFFICIAL USE or~LY 1

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(7)(C) 04/16/2015 1

Case Title : Special Project: NRC Case Number: *C 13 027 Regulatory Oversight Origination Doclink: 1j

Subject:

MTF - St. Lucie H/1 - Summary of Adverse Actions Report Date: 12/05/2014 Narrative:

MTF moved to case file 14 027 Date

!(b)(7)(C) 04/16/201 5 02:08 PM Slatus: Open Allow Other Editors: Edit Authorization:

t NRC Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(?)(C) I 04/16/2015 Case

Title:

Special Project: NRC Case Number: IC13 027 Regulatory Oversight Origination Doclink: 0

Subject:

MTF - St. Lucie H/1 Summary of Adverse Actions Report Date: 12/05/2014 Narrative:

Moved to case file 14 027 Concurred by Name Date

"""l (b.,.,.

)(7"""

)(=c ,...

) --. 04/16/2015 02:08 PM Status: Open Allow Other Editors; Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File Prepared l,y: r b)(?)(C) I 07/01/2013 Case

Title:

Special Project: NRC Case Number: C 13 027

Regulatory Oversight Origination Doclink: Cl

Subject:

NRC's Enabling Unsafe and Illegal Operations at Palisades Station Report Date: 06/19/2013 Narrative:

t)

M1 F_-Jl~ 1t1c,.rr Rev~*1,'_P,1l~adeS_Tech Specs_Lochbaum_,lune 1'9_2013_tls.doo.

From

Conclusion:

Based on OIG's review of documents related to LOCHBAUM's allegation and Palisades SIT findings and violations, it is recommended that Allegation 13-027 as part of Project 13-027 be incorporated into a new allegation for OIG i nvestigative review of Palisades technical specification violation was properly addressed and measures taken to preclude repetition.

~ I reviewed and made chan es to our memo. Please review and sign and/or

~ a n y necessary changes. (b)( )(C) /24/13).

Concurred by Name Date

..,r...)(7"'")(..,.C). ...----,1 07/24/2013 09:57 AM Slatus: Closed Allow Other Editors: Edit Authorization:

Request Review:

Approval: Approved .... l(b_)U_HC_l_ ___, 07/2412013 09:57:39 AM OFFICIAL USE ONLY 1

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OFFICE OF THE INSPECTOR GENERAL July 23, 2013 MEMORANDUM TO FILE: Case No.13-027 THROUGH:

FROM:

SUBJECT:

NRC's Handling of Pressure Boundry Leakage at the Palisades Nuclear Plant The Office of the Inspector General (OIG), U.S. Nuclear Regulatory Commission (NRC),

received a copy of a letter dated May 21, 2013, sent by David LOCHBAUM, Director of Nuclear Safety Project for Union of Concerned Scientists to NRC Chairman MACFARLANE. LOCHBAUM's letter alleges a failure by NRC to enforce regulatory requirements for reactor pressure boundary leakage at the Palisades Nuclear Plant (Palisades).

Background

Entergy Nuclear Operations, Inc., is the NRC licensee for Palisades, which is a one-reactor plant located along Lake Michigan in Covert Township, Michigan. The facility came online in 1971 and is licensed until 2031 .

The ROP (Reactor Oversight Program) collects information from Inspections and performance indicators (Pis) in order to enable the agency to arrive at objective conclusions about the licensee's safety performance. In 2011 and 2012, on a scale from 1 to 4, (with 1 being the highest performance), the highest ROP column for Palisades was 3.

OIG Review of Allegation Essentially, in his letter to Chairman MACFARLANE, LOCHBAUM claimed that the NRC failed to enforce regulatory requirements for a reactor vessel pressure boundary leak at Palisades. According to LOCHBAUM, Palisades operated with a pressure OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY -OIG INVESTIGATION INFORMATION boundary leakage longer than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> which is inconsistent with Technical Specification 3.4.13., which states the following:

N o pressure boundary leakage is allowed, being indicative of material degradation.

Leakage of this type is unacceptable as the leak itself could cause further deterioration, resulting in higher-degradation of the reactor coolant pressure boundary (RCPB).

Violation of this limiting condition for operation (L CO) could result in continued degradation of the RCPB.

LOCH BAU M's letter stated that Palisades was aware of the source of the leakage but initially opted to invoke the less restrictive technical specification limit for unknown leakage source.

Additionally, LOCHBAUM identified seven additional plants where pressure boundary leakage was reported with minimal NRC enforcement.

OIG's review of material related to this allegation disclosed that on September 5, 2012, NRC completed a special inspection at the Palisades Nuclear Plant. The inspection was conducted in response to the circumstances surrounding the steam leak on the Control Rod Drive Mechanism (CROM) 24 housing. The special inspection was initiated in accordance with Inspection Procedure 93812, "Special Inspection."

On October 17, 2012, NRC issued a report titled, "PALISADES NUCLEAR PLANT -

NRC SPECIAL INSPECTION TEAM (SIT) REPORT 05000255/2012012," which reflected that there were no findings for NRC-ldentified and Self-Revealing Findings and no findings for Licensee-Ide ntified Violations.

However, the inspection report noted three unresolved items discussed in SIT report 05000255/2012012. In particular is the unresolved item titled, Technical Specification for Primary Coolant System (PCS) Pressure Boundary Leakage." The SIT report stated:

==

Introduction:==

An unresolved item regarding TS 3.4. 13, "PCS Operational Leakage," was self-identif;ed associated with pressure boundary leakage through a cracked CROM housing.

==

Description:==

On August 9, 2012, licensee management decided a plant shutdown was necessary to investigate the source of elevated PCS unidentified leakage. At the point of the shutdown on August 12, 201 2, the unidentified leakage was approximately 0. 3 gpm and had been gradually increasing. The plant was required to be shut down per TSs when the unidentified leak rate exceeded 1.0 gpm. The NRG had been monitoring the increased trend in unidentified leakage since July 201 2, when the plant was restarted from a forced outage, to ensure that the plant was taking action as the leakage increased. The operators completed a controlled reactor shutdown on August 12, 2012.

Following containment entry, the cause of the rise in leakage was determined to *be from a steam leak originating on CRDM-24 housing. The licensee reported that the leakage 2

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION was PCS pressure boundary leakage. The TS for PCS pressure boundary leakage was 0gpm.

The licensee concluded that they operated the plant ;n a condition prohibited by TS 3 .4. 13, "PCS Operational Leakage," and reported this condition to the NRG in accordance with 10 CFR 50. 72. The NRG had previously granted enforcement discretion for situations where the licensee met all associated NRG regulations with regard to CROM nozzle inspections and the violation was the result of equipment failure that could not have been reasonably avoided or detected (Enforcement discretion was granted under EA-02-011 in 2002 for the 2001 Palisades pressure boundary leak).

Whether or not the licensee appropriately implemented their quality control program during the manufacture and installation of the CRDM-24 housing in 2001 or whether this failure was the result of an unavoidable equipment failure; is an unresolved item pending the review of the licensee's root cause evaluation. It is not known, at this time, what caused the flaw which eventually propagated.

c. Observation In review of the information in Attachment 3, the inspectors determined the failure to

_enter the off-normal procedures (ONP) for leakage was a performance deficiency. This was screened as minor since the licensee was taking appropriate action, consistent with the ONP, to address the issue.

Conclusion Recommend that OIG initiates an investigation into NRC staffs handling of the Palisades reactor pressure boundary leakage and whether the technical specification violation was handled consistent with regulatory requirements.

3 OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(7)(C) I05/15/2017 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: ']

Date: 05/ 15/2017 Note

Title:

1~ (7)(A) I Note: oved to case file l(b)(7)(E) Read Authorization: [Monitor], [Alij Allow Other Editors: Edit Authorization:

Mana emenl],.,,.l (b"""

)(?""')(""'C),...,I (b)(7) NRC ...._ ____,_

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OFFICIAL USE ONLY ChronNote Prepared by: !(b)(?)(C) I 11/13/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 j-Team: 'AIGI Primary Proactive Initiative Classification:

Origination Doclink: _j Date: 11/13/2016 Note

Title:

Case 16 016 Note: Info moved to case file l(b)(7)(E) Read Authorization: [Monitor], [All)

Allow Other Editors: Edit Authorlzat1..,.n.,.,,

Mana ement) (b )(7)(C)

(b)(7)(C) RC OFFICIAL USE ONLY

OFFICIAL USE ONLY Chron Note Prepared by: !(b )(7)(C) I IJ/ /31)016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: 'AIGI Primary Proactive Initiative Classification:

Origination Doclink: LJ Date: 11/13/2016 Note

Title:

Case 16 016 Note: info moved to case file Read Authorization : [Monitor), [All)

Allow Other Editors : Edit Aulhoriza~AQ'

[Managemenl)f (b)(7)(C) l(b)(7)(C) ~ RC .___ _ __.

OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(7)(C) !llll3/.2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: 'NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: [~

Date: 11/13/2016 Note

Title:

Case 16 O16 Note: info moved to case file r )(7)(E) Read Authoriz.ation : [Mon~or], [All) r I Allow Other Editors:

Edit Authoriza~"M

• !'+-D*- ......- ....

[ManagementWb)(7)(C)

I l(b)(7)(C) ll'lRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(?)(C)  ! 11//0/2016 Case

Title:

• Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classlficatlon:

Origination Doclink: i.,)

Date: 11/1 0/2016 Note

Title:

Case 16 016 Note: Info moved to case file l(b)(7)(E) Read Authorization : [Monitor], [All]

I Allow Other Editors:

OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(?)(C) I/ J/0912016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: ~

Date: 11/09/2016 Note

Title:

Case 16 016 Note: info moved to case file Read Authorization: [Monitor), [All]

[ Allow Other Editors:

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OFFICIAL USE ONLY ChrJJJ:J.B.ote Prepared by: ~ 10/25/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Oocllnk: l)

Date: 10/25/2016 Note

Title:

Case 16 016 Note: info moved to case file Read Authorization : [Monitor], [All)

Allow 01her Editors: Edit Authoriza.t~iooir+,;*~ .....---,

[Manage ent1](b)(Y)(C)

!(bJ(?)(C) 1

~RC '-*_ _ __,

OFFICIAL USE ONLY

OFFICIAL USE ONLY Memos to File Preparedby: l(b)(7)(C) I 04/16/2015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: l:l

Subject:

MTF - St. Lucie H/1 - summary of adverse actions Report Date: 04/1 6/2015 Narrative:

Moved to case file 14 027 Status: Open Allow Other Editors: Edit Authorization:

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY ChronNote P1*epared by: !(b)(?)(C)  ! 07/06/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: ,NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: D Date: 07/06/2016 Note

Title:

~ ~ ....u.r, 035 Note: ,__.....,..,....... requested from l(b)(?J(C)  !(OCI0/0D/IDOB/IPT) for all e-mails and documents m pu 1c and private ADAMS for 3 folks Two of the folks are 1,orela\ed to the l

case but are NRC Branch Chiefs. The 3 folks are:l(b)(?)(C) l(b)(7)(C)

• and r h)(7)(F)

Read Authorization: (Monitor), [All)

Allow Other Editors: Edit Au1horiza~ *

~ entJ}0C7)(C)

~ RC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote P,*epared by: !(b)(7)(C) 106/17/2016 Case

Title:

Special Project: NRC Case Number* C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: .J Date: 06/17/2016 (b)(7)(C)

Note

Title:

ummary

"=r 1 1 llf}Neekly Summary_June 17 2016.docx Note:

!!ii l(b)(7)(E)

Read AUlhorlzatlon: [Monitor). [All)

I Allow Other Editors: Edit Authoriz~t r *

[Managemen n7)(C)

(b)(7)(C) RC OFFICIAL USE ONLY

OFFICIAL USE ONLY Chron Note Prepared by: !(b)(?)(C) I 06/16/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classlflcatlon:

Origination Doclink: LJ Date: 06/16/2016 Note

Title:

OIG Eng Intern Note: Below are a list of assigned tasks with "Project Scope Reports":

CAs o n J u ne 13 2016 - awaited TL review.

(b)(?)(A) r r b)(7)(E)

Read Authorization * [Monitor), (All)

Allow Other Editors : Edit Authorizaliq'f..o'""

[Management), 1(b)(7)(C) l(b)(7)(C) rRc OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by:l(b)(?)(C) I 09/06/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination DocLink: ,j Date: 09/06/2016 Note Tltle: l(b)(?)(Cl !Summary Note:

(b)(7)(C) a Weekly Summary_Sept 6 2016.docx Reed Authorization: [Monitor), [All]

Allow Other Editors: Edit Authoriza..ti.,,n!"l'f....,.,.,.....,

~ ~ ~mentJ,l{)C7)(C)

(b)(7)(C) NRC -*- - -

OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(7)(C)  ! 08/30/1016 case TIUe: Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: IAIGI Primary Proactive Initiative Classification:

Origination Doclink:D Date: 08/30/2016 Note

Title:

Case 15 041 Note: On 8/30/16, ""'!

(b..,..

)(=7)..,..,

(C""") --,!and T (b)(?)(C et with OGC to discuss several legal questions related to this case . OIG describe ea legation and provided OGC with 2 documents:

OIG agreed to e-mail the "questions" that they had for OGC. Thereafter, the following e-mail was sent and received by OIG:

- ---Original Message----

From:!(b)(?)(C) I Sent: Tuesday, August 30, 2016 12:36 PM To:!(b)(7 )(C) t @nrc.gov>; _

l(b)(?)(C) I

@nrc.gov>

Cc1(b)(7J(C) Lvnrc.qov> .__ _ _ _ _ _ _ ___.-.----

Subject:

RE: Regarding OIG reques1 for Legal review and Opinion Hi !(b)(7)(C) l(b)(7)(C)

!(b)(7)(C)

Supervisory Special Agent - Investigations Team Lead Nuclear Regulatory c;;ommission Office I

at tbe losoector General l(b)(7)(C)

OFFICIAL USE ONLY

OFFICIAL USE ONLY m ny unauthorized review, use, discl on act the sender by reply e-mail or call s of the original message .

---

Original Message---

From~(b)(7)(C) I Sent Tuesday, August 30, 2016 12:30 PM To: !(bl(7J(Cl 7)""'

t @nrc.gov>;"'!(b..,. ,()... ) - - - - - - - - - - , l@nrc gov>

(c..-

Cc:!(b)(7)(C) l@nrc gov>

Subject:

RE: Regarding OIG request for legal review and Opinion H i!(b)(?)(C) I Thanks so much for meeting with us and for putting the questions in writing so we can be sure we're all on the same page with respect to the issues .

Thanks and we'll be in touch.

l(b)(?)(C) 1\101 ICE. I his e1t1a11 a1 id a, 1y atracl 111101 its 111ay co1 ,tail I co, ,fide, 1tial ,a,tteri 1c7 GlieRt er ,~erAoy Wu, k P1udoct 111atcilal. Bo net e!!i~elese eu~sicle ~IRQ wi~eyt Co~~i.sion app~gual alnrc c ov>

request for Legal review and Opinion Thanks for meeting with us. To the best of our notes, here are the questions that OIG has for OGC:

(b)(5)

OFFICIAL USE ONLY

OFFICIAL USE ONLY (b)(5)

Please keep in touch.

E~~(C) I Read Authorization: [Monitor], [All]

Allow 01her Editors: Edit Au1horizeti"""""'

[Management], (b)(l)(C)

- l (b)(7)(C) INRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by ;!(b)(7)(C)  ! 08130/)016 Case

Title:

Special Project: NRC Case Number: C 13 027 1

Regulatory Oversight Program Office: ;NRC - Entire Fiscal Year: 12013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: ')

Date: 08/30/2016 Note

Title:

Case 16 035......................

Note: Provide SAl(b)(?)(C) ~nd S (b)(?)(C) ith the following information.

Attached are 2 excel spreadsheets. One has just NMSS contracts and the 2""one has all NRC contracts. The spreadsheets are sorted by "vendor." You will see a contract for Argonne in the NMSS database and many Argonne in the "all NRC" database. For Los Alamos, there are contracts in the "all NRC" database for year ending 2015.

~

l!Jail All NRC Contract Spreadsheet_Sept 2016.xls

~

NMSS Corntract Spreadsheet_Sept 2016.xls Read Authorization! [Monfor], [Al~

Allow Other Editors: Edit Aulhorizatlon :

[Management],..,,.!

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l(b)(7)(C) !NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: j(b)(7)(C) I08/17/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classlfication:

Origination Doclink: l 1 Date: 08/17/2016 Note

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Case 16 016 Note: Based on Technical Briefing to OIG management (b)(?)(C), (b)(?)(E)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: J Date: 08/17/2016 Note

Title:

Case 16 01 6 Note: Technical Presentation

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OFFICIAL USE ONLY ChronNote Prepared by: l(b)(7)(C) I 08//6/2016 Case liUe: Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: ,NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

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Date: 08/16/2016 Note

Title:

Case 16 01 6 Note:

The e-mail below supports that IP license renewal agreed to age manage the refueling water storage tank (RWST) with no exceptions related to the RWST.

From: l(b)(?)(C) I Sent: Tuesday, August 16, 2016 1:12 PM To:!(b)(?)(Cl k§i nrc.gov>

Subject:

Indian Point RW ST Aging Management l(b)(?)(C) I As documented in Section 3.0.3.2.17 of the Indian Point License Renewal SER, the refueling water storage tank is age managed via the Water Chemistry Control - Primary and Secondary Program. Entergy added an enhancement to the program specifically for Unit 2 to monitor for sulfates monthly to ensure a concentration of <150ppb. Unit 3 did not need this enhancement because the existing program already had a monitoring provision.

Thanks, Mike NRR (b)(7)(G) r b)(?)(C) r )(?)(E)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: ..J Date: 08/16/2016 Note

Title:

Case 16 01 6 Note: Technical Briefing

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Case 16 016_Technical Briefing_August 2016.pptx rb)(?)(E)

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Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: A IGI Primary Proactive Initiative Classification:

Origination Doclink: J Date: 08/11/2016 Note

Title:

Case 16 016 7

Note: The following tasks have been completed b (b)C )CC) 1 . MTF for Senator Gillibrand Letter 2 . MTF for May ins ection report and (b)(l)(C) feeder to inspection report

3. MTF/MOI for Cb)(7)(C) transcipt.

Next steps;

1. MTF for License amendment for Refueling Water Storage Tank .

2. MTF for Rad Waste Regulations

3. MTF for Timeline 4 . Develop Technical Briefing - present week of August 15th.

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 201 3 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: I)

Date: 08/09/2016 (b )(?)(A),(b)(?)(C)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: j Date: 08/01/2016 Note

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l(b)(?)(Cl !s ummary .i Note:

~ m-1 L____JNeekly Summary_August 1 2016.docx r (7)(E)

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l(b)(7)(C)

From:

Sent: Ma 17 201612:55 PM To:

Subject:

Attachments:

........______ .,... ranscripts Transcripts May 10 2016 Teleconference - Corrected.pdf; [External_Sender) Re:

Transcript verification I corrected a few name spellings & typos and confirmed the corrections I made to the petitioner's statements with the petitioner (email attached). Attached is the corrected version of the transcripts that I'm making publicly available in ADAMS, along with the petitioner's email. I didn't feel I could add his #6 change word-for-word to the transcripts (I don't know if that's what he said since it differs a bit from the transcripts), but I'll note the info that's in his email to the PRB when we evaluate his petition.

OFFICIAL USE ONLY ChronNote Preparw by: !(b)(7)(C) I 06/06/1016 Case Title : Special Project: NRC Case Number: '. C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Docllnk : ~

Date: 06/06/2016 Note

Title:

~ 16032 No<e: 1,'

Manual Chapter. 1s name isln nd Engi~~a f Sluden/ iscussed IMC 1245 with the Lead of th is

_ OIG learned that: *

1. The Qual Journal is kept by1 e nspector until he reaches final approval/passing of Quals.

Now the Signature page from the Qual Journal is submitted to ilearn. This change took place in January 2016.

2. Prior to January 2016, Regional Technical Support Branch Chiefs oversaw the Qual Journal.

(bJ(()(Cl wasn1t sure if they kept copies of the signature pages.

1 nature pages are contained at the end of Appendix A, B, and C. The signature is for the Su ervisor who is usually the Branch Chief.

4 (b)(?)(C) contacts in rach regjon are* Regional Qual Contact- r (?)(C)

( ( )(

(b)(7)(C)

(b ( )( Rlll~ )(7)(C) t. RIVl(b)(?)(C)

IorI(6)(7)( )

n(b)(7)(C)

5. NRC began using IMC 1245 with the roll-out of ROP which was around 2000.

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: ,NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: I)

Date: 06/01/2016 Note

Title:

Case 16 032 ~

Note:

documents:

Portions of e-mail from Mr. l(b)(?)(C)

I to egarding ADAMS On June 1, 2016, I provided you two CD-ROMs that contained 2,711 DC "Sensitive" e-mail PDF files, which I downloaded from ADAMS again, a sub-set of the initial collection provided on external drive back on Februar.y 12, 2016. Because these e-mails were processed into ADAMS via the E-Mail Capture Resource applications, it highly unlikely that any of these e-mails were tampered with since February 12 (when I initially downloaded them). The E-Mail Capture Resource applications are configured to auto-add e-mails submitted and auto-declare them at the time of entry, locking down document security.

Withg)(?)(CJ I assistance today, these e-mail CD files were loaded onto your laptop. The two D-ROM discs remained in your possession.

Please let me know if you have any questions or need any further assistance.

Resp'y, Sr. Information Management Analyst Office of the Chief of Information Officer r(b)(; )(~) I 116)()()

r b)(7)(E)

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OFFICIAL USE ONLY ChronNote Prepared by: !(b)(?)(C) I 051:17/.2016 Case TitJe: Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: J Date: 05/27/2016 Note

Title:

Note: (b)(?)(C) CA l(b)(7)(cr l and S~ et to discuss the findings of the named case. (b)(?)(C) did release 2 111cen1ai obcumen~ r e d to as "observation documents" which includ es of NRC employees, during the 10 grace period. The obseNation documents described NRO's position on a NRR non-concurrence which was included wjth ,

rule-making package under Commission review. The pote

• inding is thatl(b)(7)(C) _

breached policy and did release internal NRC information. (b)(?)(C) escribed to the CA during his interview, that he believed he was being transparent a...,..""'",..,.,.'"'the release was for a good cause to ensure the Commission had full knowledge of technical information prior to their rule-making decision.

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Speclal Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: 'AIGI Proactive Initiative Primary Classification :

Origination Doclink: '1 Date: 05/26/2016 Note Tltle: Proactive Review - IP baffle bol,.....,.~.,,.,...-.

Note: - - - J -.u..J...Ju.uil,;ji,.Qav, May 26. 2016, (b)(?)(C) spoke on the phone with NRR Sr.

Engineer (b)(?)(C) [b)(?)(C) !is suppo ing egion I with the Indian Point baffle bolt situation. (b)(?)(C) learned the following :

1. Indian oin Is a estinghouse, 4-loop, "down-flow" plant. There are 7 similar plants in the U.S. They are: Units 2&3 IP, Units 1&2 Salem, Units 1&2 D.C. Cook, and Unit 1 Diablo Canyon.

2. IP found approximately 227 broken bolts (out of a total of 800+) during the 1st ever, ultrasonic (UT) inspection that is a part of the NRC Aging Management Program which is a part of license renewal. Also, most plants have license conditions to comply with a report called "MRP 227A" which requires inspections, etc.

3. Prior to license renewal, these bolts are only visually inspected until the plant is within its 25-35 full power years. Per NEI 03-08, "Industry Material Initiative," a UT inspection is due within the 25-35 full power years.

4. NEI Q3..iQ8 is not an endorsed NRC document. However, all Chief Nuclear Officers have signed it and agree to follow its contents which include inspection requirements , etc.

5. Historically, 4-loop "down-flow" plants in France experi,enced similar bolt issues. At least 4 U.S. plants voluntarily did inspections but did not find any bolt issues.

6. There use to be more than 7, 4-loop "down-flow" plants. Many changed to "up-flow" plants.

For example, Diablo Canyon 2 converted to "up-flow."

7. At I.P. the broken bolts are NOT clustered. However, at Salem they are clustered.

8. Salem is replacing all the broken bolts. A special tool is needed and only "1" is available.

This "1" tool was shipped to Salem from France. ..,,..,...,,

9. I.P. is currently determining what they are going to do. (b)t?)(C) believes they will replace enough of the damaged bolts to meet ASME code stress ImI s.

10. The root cause appears to be: Irradiation Assisted Stress Corrosion Cracking and Low Cycle Fatigue.

11 . The majority of the broken bolts are in the "middle" of the baffle plates which is equivalent to the "middle" of the fuel rods.

ma Tab B 20-16 Boxer et al. 16-0285.pdf OFFICIAL USE ONLY

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Docllnk: {j Date: 05/12/2016 Note

Title:

Allegation 16 0780 Note: To date, this allegation has not been coorelated to this project per the review comments that state:

Review Comment:

!(b)(7)(C ICheck with OE and/o~(b)(?)(C) NMSS to determine if they already rec;

• d a l l e g ~ t, provide to OE with no response. Once done, return to me to correlate to in.form (b) and close (b)( ) 12/15/15. (7)

(C l

b)(7)(E)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team; AIGI Primary Proactive Initiative Classification:

Origination Doclink: ...J Date: 05/12/2016 Note

Title:

~ Summary Note:

~

L___J lll

. eekly Summary_May 13 2016.docx l(b)(7)(E) Read Authorization : [Monitor], [Alij Allow 01her Editors: Edit Authorizatlo...

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Special Project: NRC Case Number: C 13 027

• Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: 'AiGt Primary Proactive Initiative Classlflcatlon:

Origination Doclink: j Date: 05/06/2016 Note

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l(b)(?)(A)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office : NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classlflcation:

1 Origination Doclink: j Date: 05/06/2016 Note Tltfe: Case 16 06, Note: Interview Notes l~l Case 16 016_ Interview Questions- ,.,.l (b""" )(=c ), ----..r o-1 6

)(7""'

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May 5, 2016 10:00AM C16-16

. r }(b)(?)(C) 0 uesllons LO!!

l(b)(?)(C) 1-1----------------------------

Purpose Statement:

• Allegation concerning the release of radioactive material into the groundwater al the Indian Point Energy Center.

Questions:

(b)(7)

• What is your educational background and work history? BS Chem, (C) MS Nuclear Eng, j<b)(7)(C) l- 6 years,~ 1988 July NRC- specialist io Rad Waster, Sr. HP Inspector

• Whal are your duties? 71124 all attachments - IP - over 4 years. 3 special programs - ???,

.

• l (b)(7)(C)

• Who 1s your supervisor?.__ _ _ _ _ _ _ _ _ _ _ _ _ _____.

• We received information that you were the health physicist assigned lo follow up on this matter,

• why were you selected to follow up on this matter? Lead HP Inspector at JP - fits within REM or RJTS programs.

• please walk us through wbar occurred? (staning from the point the Regjon was uotitied of the release to the preseot)----please include the who, what, when, and why.

Friday, Feb 51\ on Telework, either phone call or e-mail. IP called that they had discovered a significant tritium level. Feb I Ph spent work day at JP, During the week... be got many e-mails from NRC folks about the situation. By the Feb 11 th, 2 state representatives there and were waiting to talk to NRC. j<b)(?)(C) Ihad done a lot of leg work...tour of area wh,.e;.;,.r,.,.

e ,.,.,,,.,.--,

spill was belfovcd to be from. Met with Licensee management, etc. Did a walkdown withl(b)(?)(C) and Licensee. The Licensee has. bad ground water inspection spikes, 2010, 2012, 2014 ... significant tritium spikes during outage. NET 9707 (ground water program) - in 2014 -

weekly, bi-weekly, monthly basis. In prep for 2016 outage .. JP was starting to go back to bi-weekly sampling (January 11 th) MW30, MW31 , Monitoring Well 32, near spent fuel building... numbers were consistent with monthly numbers. Jan 26-28th**analyzed about a week later., MW 32, 12,300 to 8. lM pcurries. By the evening of Feb 4th .. *. resampling was also very high. Still very high. What does NRC req!}ire at this time?

What was the cause? Prior to outage, have a problem with RWS tank. Temporary connection to vendor skid for reverse omosis system. The reject from process, acotope, antnnonium 125, was tracer and tritium. In reject water, 80% of antimonium. Which lead to Licensee thal the reverse osmosis system was the root cause. January 17th operator found issue - was NRC aware?

Operator saw water pounng out. Licensee stopped Reverse Osmosis (RO).

- The current theory is that when the reject RO water .. ..went to floor drain ....the floor drain pip from the MOB (95') to 70'sump. Temporary pump was being pump ..... 17 blockages, portable pump, blocked floor drains, open work orders, etc. Lots of secondary spins but can't get to

May 5, 2016 I 0:00AM The latest theory - drain from 90"MOB and another drain for truck bay which goes to sump -

that sump was allowed to fill to 75' level - got back flow - which would drain into well 32.

Licensee doing a root cause ... not public yet.

Feb 11 111, 2weeks later, scheduled inspection in t51 week of March, later part of March, going back up there again.

About 10 Licensee are doing actively worldog on this as a team.

Every 2 weeks, Licensee is holding a meeting with an update Current theory - floor to joint leakage to ground under door - smu*ce of leak is backfill water from spent fuel building sump. ,Permanent sum~ p_ump had not functioned from 2014. Temporary pump (sand pump?) Was this done under 50.59? Did we approve this change from 75' 5" to 76".

This is not covered under appendix B. Rad Waste is not a safety issue. What happens when the tritium reaches its limit.

For 49 CRF for Transportation can cite, for .....no regulation to cover rad waste spills, cct. Have been using part 20, section 1400 that NRC is using for spills for radioactive spills.

• When did the region learn of this issue or was notified and by whom (regards to the leak)?

• When were you notified of this matter?

• Who assigned you to follow up on this matter?

• What were you tasked to do or your involvement, include the NRC policy and procedures you followed?

• Who else followed up. on this matter?

• What was their role, include the NRC policy and procedures they followed? Have been working this under, 71005, PI&R sample ... changing out for time for it. Well beyond inspection procedure 71124, Attachment 07 and now a PI&R sample.

• What regulations cover this situation? In 2014, had a leak, blocked floor drain..issued a licensee identified leak..... 11 months Iater ... another spike in 2015, we looked at part 20, 1406(b) which lead to a green NCV.

• Under those regs what levels of radioactive material are allowed in this circumstance (Numbers, parts per million, radiation figures, etc. if those are set in the regs)? (note: show regs)

May 5, 2016 I 0:00AM

• What levels of radioactive material actually went into the ground water and the river? (note:

compare to commissioner briefing notes)

• What ongoing follow up inspection is happening-is it a Reactive or a Special or some other specific form of inspection?

• Who is involved with this inspection?

o Were multiple inspection procedures followed?

• When will your follow up inspection activity be done and when will it be reported out?

• How will it be reported out?

• ls DRP also reporting out on the incident in the first quarter report?

• Will tbe leak/release be assigned a finding?

• What are the findings?

• What level finding (green, white ....)?

• Will there be any enforcement follow up (corrective actions)?

• What contributed lo the tritium leak?

• Is there anything else that you can tell us regarding this matter?

Reactors - "findings" - green/white/yellow/read - we "chose" not to site a violation.

~ .*

..... c_Jquest1ons I. NRC Inspection Proce<l urc 7 I 124, Attachment 02.03 Page I -

2. What are the 10 CFR part 20 limits? The problem bere is it is not part of their, 10 cfr 50. effiuent program, compliance, dose and contity . This falls into the old stuff, x.xx. However, they have included lrus in there program, RETS, it's include<l. 20,000 p ..... 14M here.. However, there are no drinking water wells on site; Hudson is salt water; so wben the Licensee did a calculation they assumed the total amount of RO waste water went to ground .. ,worse case .. .used conservation assumptfons. Calculation led to... 0.0012 milli rem.

3. NRC regulatory limits include an average concentration release limit. ..

4. NRC regulatory limits include an annual average concentration....

5. NRC regulator limits include an ALARA As Low As Reasonably Achievable) public *..

6. Why dj<ln't (b)(7)(C) ho work at Indian Point find the new tritium leak'. e on t ave an on-site samp mg program. Licensee notified them immediately.

May 5, 2016 10:00AM

7. The agency just waits for the licensee to notify it?

8. Are any NRC regulations/requirements/policy being "negotiated"?

9. Will NRC take enforcement action against Entergy for have a crucial sump pump out of service since October 2014 that could have prevented the leak and what actions will NRC take to prevent yet another tritium leak from occurring at the plant? Fixing would give you too much dose!

10. 1n addition to legal limits, are there voluntary limits or voluntary guidelines for tritium release or reporting? No ... committed to be "as low as possible." AL.ARA rule ... part 50.

11 . What is NRC's role with this leak

12. Root cause - tank cleaning up - CVS system - out of spec water - what is NRC's role?

13. There floor drain system is inadequate.... l 7 blockages, out of service, etc.

I 4. Rad waste is not safety related; outside of bounds of UFSAR.

Final questions:

• Were th~(b)(?)(C) !aware of the malfunctioning equipment that caused the leak?

• Was the malfuncboruug equipment flagged as a potential issue at any point prior to discovering the leak?

• Why was the malfunctioning equipment not repaired in 2014?

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(?)(C) !05108/20/6 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC- Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Ooclink: ..J Date: 05/04/2016 Note

Title:

~ with OIG Audits Note: ~ e t with the audit team and discussed items related to NRC's oversight of material exports.

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OFFICIAL USE ONLY ChronNote Prepared by: l(b)(? )(C) ~.5/081.2016 Case

Title:

Special Project: NRC Case Number: C 13 027

• Regulatory Oversight Program Office: *NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: .l:l Date: 05/02/2016 Note

Title:

~ with OIG Audits Note: ~ met with OIG Audits conducting 50.59 audit.

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OFFICIAL USE ONLY ChronNote Prepared by: !(b)(7)(C) I05/0'811016 Case Title : :special Project: NRC Case Number* C 13 027

,Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Tea m: AIGI Primary Proactive Initiative Classification:

Origination Doclink: J Date: 04/26/2016 Note

Title:

Allegation 16 07902 l~\

Note: Below is e-mail summarizing the review of this allegation between (C) and CA:

~

Plus .. . l have a similar allegation that I have been monitoring .

From:!(b)(?)(C)

I Sent: Tuesday, April 26, 20161:08 PM 6 7 To: !(b)(7)(C) l@nrc.gov>;Ll<_lC _l<

_c_j _ _ _ _ _ _...Jl....

ru_r~n:""'.e--"-'-ov>

cct(b)(7)(C)  !'il nre.gov>

Subject:

A 16 07902 l(b)(7)(C) I After speaking w i t ~ our recommendation is to move the allegation to her file (13-027) due to ASLB ruling on this issue sometime in the near future. After they have ruled it would probably help focus our investigative efforts if needed.

Thanks, l(b'nfifc)°otf,*":,

Special Agent - Criminal Investigator Office of the Inspector General - Investigations U .~~~;11;..1:=i.L.Wftory Commission 1i':

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OFFICIAL USE ONLY Chron Note Preparedby: j(b)(7)(C) I04/11/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: *NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: [j Date: 04/11/2016 Note

Title:

Case 16 016 Note: IP 71111 .01, "Adverse Weather Protection* Key statements include:

"71 111.01-02 INSPECTION REQUIREMENTS fpage 2] This review shall be performed for the types of weather-related risks identified for the site. The inspector should review the licensee's operating experience , corrective action program

, UFSAR, etc., to determine the types of seasonal and/or storm-related adverse weather challenges to which the site is susceptible. The actual inspection for the adverse weather condition should then be performed prior to experiencing expected seasonal temperatures extremes and when expected adverse weather conditions are imminent at the site. When selecting a sample, it is recommended that the inspector consider multiple systems that are collectively risk-significant.

[page 7] Flooding has the potential to cause common mode failure of equipment in multiple areas. Verify that the licensee has entered the problems identified during the inspection in the licensee's corrective action program. Verify that the licensee is identifying issues at an guidance.

appropriate threshold and entering them in the corrective action program . Verify that problems included in the licensee's corrective action program are properly addressed for resolution. See Inspection Procedure 71152, "Identification and Resolution of Problems," for additional IP_IP 71111 .01_Adverse Weather Protection_Ml 14343A684.pdf Ell..,

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OFFICIAL USE ONLY ChronNote Prepared by: (b)(?)(C) 04/lll1016 Case

Title:

Special Project: NRC Case Number: C 13027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classificatlo11:

Origination Doclink: ~

Date: 04/11/2016 Note

Title:

OIG 50.59 Audit Note: [(b}(7il..vas briefed by l(b)(?)(C) I regarding the 50.59 audit OIG is conducting.

~ uggested t~ dits review all the Special Inspections performed in the last few years and

~ ermine if the equipment that failed was (1) previously inspected by NRC and/or (2) recently modified under 50.59. Also~ suggested Audits review the last 3 years of LERs and determine the same. Henc~ the equipmeT tht failed was (1) previously inspected by

_________ NRC and/or...{2).re.cently modified under *S0:59: *

• lso provided information regarding "additional guidance" industry utilizes. Meaning, NEI 96 07 is not the only guidance used by Licensees.~ gree to obtain the name of the additional guidance. Overall, it appears this audit is leacttr;g'to many lose ends that appear to impact the effectiveness of NRC oversight of 50.59. Also, 50.59 audits might be eliminated per Project AIM.

Read Authorization: (Monitor), [Alij Allow Other Editors: Edit Author1za~

ent]~

RC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by:!(b )(7)(C) ~ /1112016 Case Title : Special Project: NRC Case Number : C 13 027 Regulatory Oversight Program Office: ;NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: i)

Date: 04/11/2016 Note

Title:

1~~{7) Isummary Note:

(b)(?)(C) ~I eekly Summary_April 11 2016.docx r (?)(E)

Read Authorization: [Monitor], [All]

Allow Other Editors: Edit Authoriza~

[Management),~

(b)(?)(C) NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prcpared b_y: l(b)(?)(C) I 02107/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: i)

Date: 02/05/2016 Note ntle: ~ Summary Note: ~

a~I eekly Summary_Feb 5 2016.docx Read Authorization: [Monitor), [All)

Allow Other Editors: Edit Authorization:

OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(7)(C) I0//29/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 1Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink : Cl Date: 01/29/2016 (b )(7)(A),(b)(7)(C)

OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(?)(C) I 01/28/2016 Case

Title:

Special Project: NRC Case Number: C 13 027

,Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Docllnk: :)

Date: 01/28/2016 (b)(7)(A)

Read Aulhorizatlon: [Monitor], [All) 1Allow Other Editors: Edit Authorization:

OFFICIAL USE ONLY

OFFICIAL USE ONLY Audit Work~a~er Prepared by:!(b)J) C) p1106/2010 AudltTltle: 20 10 Audit of NRC's Non-Concurrence Process Objective -S.01 .B.01 a Objective Name: Survey Designation:

Origination Doclink: Ls finding Doclink-

Subject:

MD 10.158 Subsection:

Enter the workpaper information below PURPOSE: To document agency policy pertaining to the implementation of the Non-Concurrence Process (NCP).

SOURCE: Management Directive (MD) 10.158, "NRC Non-Concurrence Process (Draft)

Interim Guidance," draft issued November 29, 2006.

Auditor's Note: A finalized version of MD 10.158 has not been published to date.]

~ : 0r, ftNon-Concurrenc~PoNcy pa/

Downloaded from the NRC Web site:

http://www.internal.nrc.gov/ADM/DAS/cag/mandirs/mddocs/md10.158.html DETAIUANALYSIS:

[ numbers in brackets refers to PDF pages and subsection of Attachment 1 on which the information can be found .]

I. MD 3.5

1. Policy: [4,10.158-01]

The U.S. Nuclear Regulatory Commission (NRG) promotes discussion and consideration of differing views in the preparation and review of agency documents. Individuals have various mechanisms for expressing their views about agency decisions. This directive and associated handbook describe a Non-Concurrence Process (NCP) for eligible individuals with concerns about documents in the concurrence process that they had a role in creating or reviewing. -This directive complements Directive 10.160, "Open Door Policy," and Directive 10.159, "The NRC Differing Professional Opinions Program," and relies on provisions of Directive 3.57, "Correspondence Management."

Mot fer ~eleeee it, ADAMS OFFICIAL USE ONLY

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2. Objectives: (4, 10.158-02)

• To promote discussion and consideration of differing views on documents n the concurrence process.

• To provide a non-concurrence option for individuals with concerns about documents in the concurrence process that they had a role in creating or reviewing.

• To provide a uniform approach to pro,cessing non-concurrences.

3. Organizational Responsibilities: (4-5, 10.158-03, 031)

A.EDO

• For documents signed by EDO, reviews NCP Form and other relevant information, and either signs document or returns to document sponsor for additional action.

• For documents being signed and transmitted to Commission:

• At a minimum, provides records of all non-concurrences as background information.

• Determines whether to make explicit reference to non-concurrence and provide records as enclosures B. Office Directors and Regional Administrators (5, 10.158-03, 032)

• Ensure that non-concurrences are processed in accordance with this directive and handbook.

• For documents they are signing, review NCP Form and other relevant information, and either sign documents or return to document sponsor for additional action.

• For documents signed and transmitted to OEDO:

• At a minimum, provide records of all non-concurrences as background information.

• Determine whether to make explicit reference to non-concurrences and provide records as enclosures.

• Prior to making non-concurrence records publicly available, assure that records are screened in accordance with all requirements related to public release of agency records.

C. Director, Office of Enforcement (5, 10.158-03, 033]

• Maintains this directive and handbook

• Provides guidance on implementation of the NCP.

• Conducts periodic assessments to evaluate the adequacy of this directive and handbook.

• makes recommendations to OEDO for changes to this directive and handbook.

4. Definitions (6, 10.158-04]

1. Document Sponsor: The manager or team leader responsible for originating and controlling changes to a document that is in the concurrence process and is the subject of a non-concurrence. [Auditor's Note: Based on the definition provided, it does not appear that the document sponsor is also the document originator (writer.)]

t>lot tor rol80&8 in :O.GlAr>.4~

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2. Non-concurrence: The act of formally indicating disagreement with a document in the concurrence process that hte individual had a role in creating or reviewing.

3. Withdrawal of non-concurrence: The voluntary act by a non-concurring individual to withdraw a non-concurrence, resulting in the discontinuation of the Non-Concurrence Process.

5. Applicability (6, 10.158~05]

This directive and handbook apply to all NRC headquarters and regional office employees except NRC boards and advisory committees that report directly to the Commission.*

6. Introduction [9, A , 1]

The U.S. NRC promotes the expression and discussion of differing views in the preparation and review of agency documents. Individuals have various mechanisms for expressing their views, including informal discussions, the Open Door Policy described in Directive 10.160, and the Differing Professional Opinions (DPO) Program described in Directive 10.159. This directive and handbook describe a Non-Concurrence Process for eligible individuals with concerns about documents undergoing review and concurrence.

This directive relies substantially on Directive 3.57, "Correspondence Management," for guidance on the concurrence process.

7. Relationship of NCP to Open Door Policy and DPO Program (9, A, 2]

The NCP complements the other mechanisms fo raising concerns.but is not as broad as

• the Open Door Policy because the NCP applies only to concerns about documents in concurrence and may be used only by individuals who are eligible to non-concur. The Open Door Policy can be used by any employee to discuss "any work-related issue or concern" with agency supervisors and managers. The NCP also differs from the OPO Program because the NCP can be used to challenge positions in draft documents, before a final position is established . The DPO Program applies only to positions that are no longer under staff review, and has certain prerequisites and exclusions that do not apply to the NCP.

8. Expectations for Informal Discussions Prior to Using NCP (9, A, 3]

All employees-including those who may not be eligible to use the NCP-have a responsibility to express and discuss differing views as early as possible in the preparation and review of agency documents. Individuals with concerns and those responsible for originating and issuing documents, including document sponsor.sand signers, have a responsibility to seek solutions to concerns that might otherwise result in a non-coocurrence. Non-concurrence should be necessary only when informal discussions are unable to resolve an individual's concerns and the individual seeks a response through the NCP. *

9. Applicability of Non-Concurrence Process [9-10, 8, 1)

The NCP applies to all documents in the concurrence process, including those that require review and concurrence by multiple NRC offices before issuance. Special considerations apply to documents being transmitted by an .office director to the OEDO or by OEDO to the Commission.

10. Eligibility to Use the NCP (9-10, B, 2]

4et ter releeoe iii. A9Al'w4S OFFICIAL USE ONLY

OFFICIAL USE ONLY NRC headquarters and regional employees, except members of boards and advisory committees reporting to the Commission, may non-concur in a document. Their views will be considered in accordance with the NCP provided the following criteria are met :

• The document is undergoing review and concurrence.

• The non-concurring individual is one of the following:

• the author of the document;

• on document concurrence;

• a contributor tasked with providing document content; or

• a reviewer tasked _by the document sponsor or a supervisor to review the document.

(Auditor's Note: It is unclear how an individual that is tasked with providing document content or reviewing the document but is not listed on the concurrence page, indicates or documents their non-concurrence.]

11 . Individuals Not Eligible to Use the NCP [10, B, 3]

Individuals who are not eligible to use the NCP are encouraged to use informal discussions and the Open Door Policy to express their concerns to the document sponsor, document signer or other managers involved in the document concurrence process.

12. Description of Non-Concurrence Process [10, C, 1]

The NCP is a three-part process: 1) the initiation of a non-concurrence; 2) the document sponsor's review; and 3) the document signer's review. The following is a basic description of the NCP beginning with the initiation of a non-concurrence.

a. Part 1-lnitiation of a. non-concurrence [10, C, 2]

• Non-concurring individual informs own supervisor and document sponsor that NCP is being initiated

• Non-concurring individual indicates non-concurrence on document concurrence page, and describes reasons for non-concurrence on NRC Form 757

• Non-concurring individual sends form to own supervisor and document sponsor [Auditor's Note: It is unclear if this Form Is sent to each individual simultaneously or individually so that each person can make comments on the form as necessary).

• Non-concurring individual's supervisor uses.NCP Form to provide any additional information to be considered by the document sponsor

b. Part 2-Document sponsor's review [10, C, 3]

• Document sponsor reviews information provided by non-concurring individual and individual supervisor

• Document sponsor confers with others , including the document signer, as necessary

• Document sponsor uses NCP Form to describe proposed actions, if any, to address non-concurrence

• Document sponsor places NCP Form in document package and:

• returns revised document to non-concurring individual and others who previously concurred , in accordance with MD 3.57, or

• returns unrevised document to concurrence process Not IOI release 111 ,:<1,A:~l~

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c. Part 3- Document signer's review [11, C, 4)

• Document signer reviews NCP Form and all. relevant information

• Document signer confers with others, as necessary

• Document signer either signs document, indicating agreement with the proposed actions, or returns document to document sponsor for additional action.

13. Individual Responsibilities for NCP [11, D, 1]

Individual employees, managers, document sponsors and document signers all have a responsibility for assuring that any differing views that are expressed are considered in the document preparation and review process, and that the NCP, if initiated, is effectively and efficiently implemented. The following is a summary of those responsibilities .

a. All Employees [11, D, 2]

• Raise concerns-and propose solutions- as early as possible in the document preparation and review process.

• Discuss differing views with own supervisor and the document sponsor before initiating non-concurrences.

• Initiate and document non-concurrences in accordance with this handbook.

• Be clear and succinct in describing reasons for non-concurrence on NCP Form

b. All Team Leaders, Supervisors and Managers [11-12, D, 3]

• Encourage individuals to express concerns-and to propose solutions-as early as possible in the document preparation and review process.

• Make individuals aware of all of their options for expressing and resolving differing views, including informal discussions, the Open Door Policy, the NCP, and the DPO program.

• Assure that individuals who have expressed differing views are not excluded from further discussions of an issue and are not treated disparately.

• Consider recogni.t ion of individuals whose expression of differing vi.e ws has resulted in an improved outcome or made a valuable contribution to the decision-making process.

• Do not hold non-concurring individuals, document sponsors or others involved in the NCP accountable for delays in document issuance provided they endeavored to meet their responsibilities as described in this handbook.

• Adjust document schedules, as neoessary, to allow adequate time for addressing non-concurrences in accordance with the requirements of this directive.

• Provide timely input to document sponsors if providing information related to an individual's non-concurrence.

c. Document sponsors [12, D , 3)

For the purpose of this directive, document sponsors are defined as the team leader or manager responsible for originating and controlling changes to a document in the concurrence process. Although similar to the concept of "document originator" in MD 3.57, the document sponsor is assumed to have control over changes to a document and is given significant responsibilities for l~ot fo, , elease ii 1~D~MS OFFICIAL USE ONLY

OFFICIAL USE ONLY implementing the NCP. These include:

• Discuss document concerns with individuals and seek solutions to address concerns that might otherwise result in a non-concurrence.

• Remove individuals from document concurrence [Auditor's Note: It is unclear whether an individual's request to be removed from concurrence must be documented and included in concurrence package.]

• Confirm that non-concurring individuals are eligible to use the NCP

• Inform management, including own supervisor, as appropriate, upon receipt of a non-concurrence.

• Review and process non-concurrences in accordance with this handbook.

• At the conclusion of the NCP, inform non-concurring individuals of the outcome.

• Make document signer aware of any important concerns expressed by individuals who chose not to, or were not eligible to, pursue a non-concurrence, including concerns that formed the basis for a request for removal from concurrence. [Auditor's Note: What assurance is there to ensure this happens? Is documentation required?]

d. Document signers [12-13, DJ

• Review and process non-concurrences in accordance with this handbook

• Conduct final reviews of non-concurrence

• For any important concerns expressed by individuals who chose not to, or were not eligible to, pursue a non-concurrence, including concerns that formed the basis for a request for removal from concurrence, determine whether action should be taken to address the concern or communicate it to others.[Auditor's Note: The term "iimportant concerns" is not defined and therefore is left open to *subjectivity and individual interpretation.]

14. Additional Implementation Guidance [13-19, E]

a. Timeliness of NCP [13, E, 1) i.) This handbook establishes no specific time limit for the review of non-concurrences. The intent is to resolve non-concurrences as part of the normal document concurrence process and in accordance with the normal document schedule.

In all cases, the review of non-concurrences shall be complete before the document is issued.

ii.) All employees involved in this process have a responsibility to make the NCP as timely, efficient and effective as possible. Concerns should be promptly raised and thoroughly and promptly addressed. Information provided to support the NCP, whether from a non-concurring individual, the individual's supervisor, or another office, should be provided in a timely manner. In addition, all parties should endeavor to be succinct in completing NCP forms and related records ; only information which is necessary to make or support a decision on a nonconcurrence should be provided.

iii. Notwithstanding efforts to be prompt, the NCP requires that certain actions occur before a document can be issued, and some documents may be delayed beyond their normal schedules. Document sponsors should adjust document schedules, as necessary, to allow adequate time to address non-concurrences in accordance with the requirements of this directive. Non-concurring individuals, document sponsors and

~dot Fu, ,cleese ii, ADAMS OFFICIAL USE ONLY

OFFICIAL USE ONLY others involved in the non-concurrence process shall not be held accountable for delays in document issuance provided they endeavored to meet their responsibilities as described in this handbook. In evaluating such efforts, managers should recognize that in some cases the first opportunity individuals have to clearly formulate their concerns is when a document is presented to them for review or concurrence .

b. Removing Individuals from Document Concurrence [13-14, E, 2]

i.) Individuals on document concurrence may be removed from concurrence based on redundancies in the concurrence chain, unavailability to review a document, or document concerns that do not, from the individual's perspective, warrant nonconcurrence. Document sponsors normally should remove individuals at their request, but must assure that the document concurrence chain remains appropriate based on the document's subject matter.

In no case should a document sponsor remove an individual from document concurrence to avoid a non-concurrence.

ii.) Individuals on document concurrence may request removal by:

• Manually or electronically marking through , or entering the word "Remove" in, their concurrence block, without initialing or dating the block, as indicated in the example below; or

• Asking the document sponsor to remove their name and concurrence block from the document.

[Auditor's Note: See document page 6 for graphic].

iii.} If removal from concurrence is requested, the individual's concurrence block shall be completely removed from the official record copy of the document.

iv.} Individuals who request removal from concurrence based on document concerns should be encouraged - but not required - to use the NCP to address their concerns. However, removal from concurrence is not a non-concurrence for the purpose of this directive and handbook, and the provisions of the NCP should not be followed . Document sponsors have a responsibility to make the document signer aware of any important concerns that formed the basis for a re-q uest for removal from concurrence.

• c. Initiating Non-Concurrences [14 , E,3]

i.) To initiate a non-concurrence, individuals shall:

• Inform the document sponsor and their own supervisor. [Auditor's Note: It is unclear why a supervisor must be informed if the supervisor is not also responsible for sponsoring or signing the document in question. Requiring a supervisor's signature may also deter one from using the NCP .]

• Enter the non-concurrence on the document concurrence page, as discussed below.

• Complete Section A of the NCP Form and submit the form to the document sponsor with a copy to their own supervisor.

d. Indicating Non-Concurrence on Documents [15, E, 4]

i. Indiv iduals on document concurrence who non-concur shall, Net fer releooe iR iA,D.A,MS OFFICIAL USE ONLY

OFFICIAL USE ONLY

• Manually or electronically enter Non-Concur" in their concurrence block.

• Manually or electronically initial and date the block.

[Auditor's Note: See Attachment I PDF page 15 for graphic].

ii. The electronic, official record copy of the concurrence page shall include the same information. Adding the term "Non-Concur" may require adding a line to the "Name" row in the concurrence table.

iii. Individuals who are not on document concurrence, such as document reviewers and contributors, shall:

• Manually or electronically enter their organization and name on the document concurrence page, or a copy of the document concurrence page.

• Manually or electronically enter "Non-Concur," and initial and date it. Provide this information to the document sponsor and request that a concurrence block be added to the official record copy of the document to record the non-concurrence. _

• Provide this information to the document sponsor and request that a concurrence block be added to the official record copy of the document to record the non-concurrence.

iv. The electronic, official record copy of any document on which there a non-concurrence shall include:

• A concurrence block for the non-concurring individual.

• The individual's name and organization.

• The term "Non-Concur," and the date of the non-concurrence. If a non-concurring individual subsequently concurs, the concurrence page shall be modified accordingly, and the official record copy of the document shall not indicate that a non-concurrence was associated with the document.

e. Using the NCP Form [15-17, E, 5]

i. NRC Form 757, "Non-Concurrence Process," is available from the NRC's forms management system and shall be used to facilitate the NCP.

Individuals, their supervisors and document sponsors should be succinct in describing the reasons for, and actions taken to address, non-concurrences.

ii. The form may be filled out and transferred electronically or printed and filled in by hand. If the non-concurrence involves classified, safeguards, or sensitive unclassified, non-safeguards information, the form shall be mar ked and handled in accordance with the appropriate requirements. Once initiated, the form shall be completed and processed in the following manner:

• The non-concurring individual shall complete Section A, which records basic information about the document, identifying1 information about the nonconcurring individual, and the reasons for non-concurrence. Section A also should be used to describe P~ot fo1 , elease ii I Ar5Aft'l~

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OFFICIAL USE ONLY proposed alternatives. The non-concurring individual shall submit the form to the document sponsor, and simultaneously provide a copy to his or her own supervisor.

• The individual's supervisor shall complete Section B, which records information the individual's supervisor (or organization) wants the document sponsor to consider. Providing this information is optional. However, whether or not information is provided, the supervisor shall complete Section Band send it to the document sponsor.

• The document sponsor shall complete Section C, which records actions taken to address the non-concurrence, and, at the bottom of the page, the status of non-concurrence. If no actions are taken, the reasons should be recorded.

• Section C shall be revised to reflect changes in the actions taken to address the non-concurrence, or in the status of the non-concurrence (e.g., if the non-concurring individual later concurs or withdraws the non-concurrence). The document sponsor shall assure that Section C is current before declaring the NCP Form an official agency record.

• Section D of the form shall be used as a continuation page for Sections A, Band C, and the check boxes at the top of the page shall be used to indicate which section is being continued . If more than one section is continued, each shall be continued on a separate page and marked to indicate which section of the form 'is being continued.

• The document sponsor shall place a copy of the completed form in the document concurrence package. If the non-concurring individual continues to non-concur, the form shall be placed immediately behind the concurrence page. If the non-concurring individual concurs or withdraws the non-concurrence, the form shall be placed in the background section of the concurrence package. *

• All forms are official agency records (although normally non-public) and shall be maintained in accordance with Section G .

f. Reviewing Non-Concurrences [17-18, E, 6]

i. The following guidance applies to document sponsors and document signers involved in reviewing non-concurrences:

• The document sponsor shall, at a minimum, consider input from non-concurring individual and any additional information provided by the individual's supervisor before deciding what, if any, actions should be taken to address a non-concurrence.

• To preclude process iterations, the document sponsor should confer with interested parties, including others on document concurrence and the document signer, before completing Section C of Form 757.

• The document sponsor may request assistance from other offices if the expertise needed to resolve a non-concurrence resides elsewhere in the agency.

• The document sponsor shall describe proposed actions to Net fer Feleaee in .o.gAl\4i OFFICIAL USE ONLY

OFFICIAL USE ONLY address the non-concurrence in Section C of the Form. If no actions are taken, the reasons should be included on the form .

• If the document is revised to address the non-concurrence, the document sponsor shall return the revised document to the non-concurring individual and others who previously concurred, in accordance with MD 3.57.

• If the document is not revised to address the non-concurrence, the document sponsor shall return the document to the concurrence process, with the NCP Form behind the concurrence page in the package.

• The *document signer shall review all information relevant to the non-concurrence, and may confer with interested parties, as necessary, before making a final decision on the non-concurrence. The document signer shall either sign the document or return it to the document sponsor for additional action.

• If the document signer and document sponsor are the same, the final review of the non-concurrence shall be elevated to the next level of management within the organization, and the reviewing manager shall be added to document concurrence.

• If the document signer is not a Senior Executive Service (SES) manager, the final review of the non-concurrence shall be elevated to the first SES management level above the document signer and the reviewing manager shall be added to document concurrence.

• At the conclusion of the process (i.e., after the document signer has made a final decision on the non-concurrence, the document sponsor shall inform the non-concurring individual, and assure that the NCP Form accurately reflects actions taken to address the non-concurrence and the final status of the non-concurrence (non-concurring individual either concurs, non-concurs or withdraws) before declaring the form an official agency record .

g. Processing Documents With Non-Concurrences [18-19, E, 7)

i. The document concurrence process may cofltinue if a non-concurrence is initiated. However, the steps taken will depend on the circumstances. The following guidance applies:

• A document that is in sequential concurrence (i.e., moving from person to person) should not be permitted to move forward in the concurrence process until a proposed disposition of the non-concurrence is formulated and the NCP Form is placed in the document concurrence package. The provisions of MD 3.57 apply.

• If a document is sent out for parallel review and concurrence, and a non-concurrence is initiated by one of the reviewers , the document sponsor has discretion in deciding how to continue with the concurrence process.

• If the issue involved in the non-concurrence is one of the general interest, the document sponsor should consider informing the other reviewers and requesting their views Not for release in ADAIOI-'

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OFFICIAL USE ONLY on the issue

• If the issue involved in the non-concurrence is of limited interest to other reviewers, the document sponsor may allow the review and concurrence process to continue, but is obligated to re-circulate the document to them if the non-concurrence results in substantive changes.

ii. For documents being signed and transmitted to either the OEDO of the Commission, records of all non-concurrences shall be provided as background information or as enclosures.

h. Withdrawing Non-Concurrences [19-20, E, 8]

I. A non-concurring individual may withdraw a non-concurrence at any time prior to the issuance of a document by informing the document sponsor. If a non-concurrence is withdrawn:

• The NCP Is discontinued, and the involved document shall be processed as if there were no non-concurrence associated with it.

• The document sponsor and document signer have no further obligation to review the non-concurrence.

• Section C of the NCP Form shall be revised by the document sponsor to indicate the non-concurrence is withdrawn, and the current version of the form shall be placed in the background section of the document package and retained as an agency record. If the non-concurrence is withdrawn before the NCP is completed, the document sponsor should note this in Section C of the Form.

• The concurrence page for any document involving a withdrawn non-concurrence shall be revised to eliminate any Indicating of the non-concurrence, The non-concurring individual shall either:

• Indicate concurrence on the document; or

• Request to be removed from document concurrence in accordance with Section E.2., "Removing Individuals from Document Concurrence."

• If a document involving a withdrawn non-concurrence is being signed and transmitted to either OEDO or the Commission, records of the withdrawn non-concurrence shall be provided as background information or as an enclosure in accordance with Section F.

15. Submitting Documents to OEDO or Commission [19-20, 10.158-05, F]

i. If a document involving a non-concurrence is being prepared for signature by the EDO, the process described above is fully applicable. In particular, as the document signer, the EDO would review all information relevant to the non-concurrence, confer with interested parties as necessary, and either sign the document or return it to the document sponsor for additional action.

ii. The primary objective is to assure that OEDO and the Commission are made aware of non-concurrences and how they were addressed by the staff, especially in cases where a recommendation is being made .to OEDO or the Commission. COMSECY-050045 (ML061810497}, dated June 30, 2006, states that "Staff papers and memoranda coming to the Commission should include any significant differing opinions that arose during the i<Jot tar release ill ADAIOI~

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OFFICIAL USE ONLY process."

iii. If a non-concurrence is associated with a document being signed out by an office director or regional administrator to OEDO, or by OEDO to the Commission. the following guidance applies:

• Records of all non-concurrences-including those addressed to the satisfaction of the non-concurring individual and those that are withdrawn-shall, at a minimum, be transmitted with the doctJment as background information.

• Whether to make explicit reference to a particular non-concurrence, and enclose the associated records, is within the discretion of the document signer.

16. Keeping Records of Non-Concurrences [20, 10.158-05, G]

i. The document sponsor's organization is responsible for record-keeping associated with the NCP.

ii. All NCP Forms and other records created to document non-concurrences are official agency records. Thus, all non-concurrence records , including records of non-concurrences that are subsequently withdrawn:

• Shall be retained in ADAMS, or other record retention systems if ADAMS is not the appropriate repository

• If retained in ADAMS, shall be profiled in accordance with ADAMS template NRC-006 and shall be included in a package with the final version of the document that was the subject of the non-concurrence.

• If retained in paper record retention systems, shall be co-located with the final version of the document that was the subject of the non-concurrence.

• Shall be retained on the same retention schedule as the document that was the subject of the non-concurrence.

• Shall normally be non-public, even if the document they are associated w ith is publicly available, unless subject to special requirements. [Auditor's Note: It is not clear why if the document is publicly available, and listed as such in ADAMS, why the all corresponding process documents (Form 757) would not also be made public.)

• Based on unique licensing requirements, the need to make non-concurrence records associated with the high level waste repository program publicly available is governed by the provisions of 10 CFR Part 2, Appendix J.

• Subject to all other requirements related to the public release of agency records, may be made publicly available at the request of the non-concurring individual or in response to a Freedom of Information Act request. [Auditor's Note: Based on point 16 ii, fifth bullet, it is not clear if a non-concurrence would only be made public if subject to special requirements or if requested by the non-concurrer.]

17. Prohibition of Retaliation (20-21 , 10.158-05, H]

Retaliation against individuals who non-concur is prohibited and may result in disciplinary action. Employees who believe that retaliatory actions have been taken because of their non-concurrence may seek redress through the negotiated grievance procedure (Article 51 of the Collective Bargaining Agreement) or through the grievance procedure described in MD 10.101 blot fQr roloa1to in OPM1~

OFFICIAL USE ONLY

OFFICIAL USE ONLY

SUMMARY

/CONCLUSION:

1. MD. 10.158 is still in draft form (See Source section)

2. An individual must be eligible to use the Non-Concurrence Process. Specifically, s/he must be a signer or reviewer of the document. Additionally, the NCP may only be used when the document is in the concurrence process. (See point 10}.

3. Documentation substantiating an initiation of non-concurrence (i.e. Form 757} is to be included in the document's concurrence package and to retained as an official agency record .

(See points 14,g and 16 ii.)

4. Non-Concurrences are generally not public. (See point 16, ii fifth bullet}.

COMMENTS:

H'istory Slatus: Approved Request Review:

In Progress Edit  !(b)(7)(C) !NRcJ(b)(7)(C) NRC Current Editor List:

I(b)(7)(E) I Reed Authorization: !All],, [Monitor]

Level 1 Approval:

Level 2 Approval: Approved  !(b )(7)(C) 01/1312010 12:31:38 PM f4ot FOi I elease Ii 1 .t<r,.t<~I~

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OFFICIAL USE ONLY ChronNote Prepared by: l(b)(7)(C) 101/25/2016 Case Title : Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: *NRC

• Entire Fiscal Year: 2013 Team: 'AIGI I

Primary Proactive Initiative Classification:

Origination Doclink: ')

Date: 01/25/2016 Note

Title:

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Title:

,Special Project: NRC Case Number : C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 I

Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink : j Date: 01/22/2016 Note

Title:

l(ti'i('nls u mmary lifL..J ~

Note:

FcFl m~1 see attached L JWeekly Summary_Jan 22 2016.docx Read Authorization: [Monitor), [All)

Allow Other Editors: Edit Authorization:

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OFFICIAL USE ONLY Chron Note Preparedby: l(b)(7)(C) 101/15/1016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classtfication:

Origination Doclink: l.J Date: 01/15/2016 Note

Title:

Allegation 25-07552 Note: Preparing to interview the alleger. Will develop a time line of events and goals/objectives for the interview based on review of all the information provided. Between the information provided by the alleger and information gathered for this allegation, there is over 1000 pages to review.

Read Authorization: [Monitor], [A.II]

Allow Other Editors: Edit Authorization :

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Special Project: NRC Case Number : C 13 027 Regulatory Oversight Program Office: NRG - E*ntire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: .J Date: 01/15/2016 Note

Title:

~ Project Note: ~ dination for (b)(?) Report Review at Cooper (D)

Froin (b)(7)(C)

Sent: n ay, anuary 5, 2016 10:26 AM To:l(b)(7)(C) l@nrc.gov>

Cc: _(b)(7)(C) l@nrc.gov>; !(b

...._)_

(7_)(_C_) - - - -~nrc.gov>

Subject:

Cooper visit point of contact (b)(7)(C)

Good morning Per our discussion, I have a point of contact scheduled for you for your Cooper visit on 2/10-2/12/2016. Your POC is:

rb)(7)(CJ He has your contact information as well. He~,~:rciled in those dates and he will be working on getting you an (b)(7 )(C) et up to review th eport in the admin building that is onsite (outside of the pro ec e area). He will await all/email, but if he doesn't hear from you in the next week or so, he said he will r,each out to you .

Please let us know if you need anything else associated with your visit (schedule a meeting, etc.). Thanks Coo er Nuclear Station (b)(7)(C)

(b)(7)(C)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Ooclink: LJ Date: 01/15/2016 Note

Title:

OIG Training Note: Notes from mtg with Training BC:

G105 - SDP 7 (b)(?)(C) I- Sr ~ will send course outline & pre-read material - l(b)(?)(C) I at~end S201- 36 hr course - Materials Controls, Security Systems & Principles - possible to get in .... May 16 ,

td ~

May 23 , and August 8 (Albuquerque, NM)

(b)(?J(Cl Primarily on Material Security, Part 37, 2 ours o see ow oca 1censees are inspecte Seminar ID_4761- Fuel Cycle Pr ocesses (3-day seminar) -offered as needed .... headquarters might do for us. (b)(?)(C) will let US know. ilearn states, "Item

Description:

This 3-day seminar provides familiarity with the nuclear fuel cycle rom uranium mining to fuel fabrication. It covers uranium mining and In situ leac~ extraction; uranium mllling; uranium conversion, and fuel fabric;ation. It also covers special topics such as hazards associated with fuel cycle operations, special sampling concerns (e.g.

r epresentative sampling); and special securlty concerns for the fuel cycle .."

OIG 3-Yr Training Plan for Team 2 (b)(?)(C) ev1_Jan 2016.docx mg...

RIC 2016 Sesslons_OIG attendee.pelf l a"-

SnlpimagejPG RIC 2016 Session_ Meeting Minute Template.pdf Read Authorization: [Monitor), [All]

Allow Other Editors: Edil Authorlz.atlon:

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1Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination DocUnk: Ll Date: 01/13/2016 Note: Each of the Note

Title:

Case 16-013 embedded documents Note: Documents referenced in the allegation: are publicly available.

~

Proposed Rule 79FR43284.pdf

~

Proposed Rule 80FR25237.pdf ea-

~

SECY 08-0197_ML090920103.pdf

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SECY 12-0064.pdf

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SRM-SECY-08-0197_ML12352A133.pdf ' - - - - - - - - - ~

~

SRM-SECY-12-0064 .pdf l(b)(7)(E) Read Aulhorlzation: [Monitor), [Alij Allow Other Editors: Edit Authorization:

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OFFICIAL USE ONLY ChronNote Prepared by: l(b)(7)(C) j12122f2015 Case

Title:

Special Project: NRC Case Number: C 13 027

'Regulatory Oversight Program Office: 'NRC I

- Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classiflcatlon:

Origination Doclink: 1 Date: 12/22/2015 Note

Title:

Case 16-012 Note: info moved to case file Read Authorization: [Monitor), [AIIJ

, Allow Other Editors: Edit Authorization Mana ementJ,l(b)(7)(C)

(b)(7)(C) NRC

• OFFICIAL USE ONLY

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,Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: ,NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: L)

Date: 12/22/2015 Note

Title:

A15 07758 Note: info moved to case file Read Authorization: [Monitor], [AIO Allow Other Editors: EdltAuthorizau..,

• on...,:=,,......,

[Mana ementJ!(b)(7)(C)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: CJ Date: 12/18/2015 Note

Title:

Case 14 027 Followup Note: info moved to case file Read Authorization: [Monitor!, [All)

Allow Other Editors: Edit Aulhori...,'ll*~ * ,,.,,.,--,

[Management) (b)(7)(C)

(b)(7)(C) NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(?)(C) I/}/1812015 Case lltle: Special Proj ect: NRC Case Number: C 13 027

,Regulatory Oversight Program Office: NRC

• Entire Fiscal Year: 2013 Team: 1AIGI Primary Proactive Initiative Classification:

Origination Doclink: '.3 Date: 12/18/2015 (b)(?)(A)

Note ntle:

Note:

Read Authorization: [Monitor), [All]

Allow Other Editors:

Edit Authorizali~

[Management), (b){7)(C i~~r) INRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(7)(C) 112/1812015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: ~

Date: 12/18/2015 Note

Title:

OIG Training - Reactor Concepts Part 1 Note:

~

Reactor Concepts Training_Dec 2015 - jcp.pptx 131'-

.... J-OIG_Reactor Training_Notes for Fukushima_Dec 2015.pdf OIG_Reactor Training_Scenario #1_Dec 2015.pdf r )(7)(E)

Read Authorization: [Monitor], [All]

Allow Other Editors : Edit Authoriza~* *

[Management], (b)(7)

(b)(7)(C) RC C OFFICIAL USE ONli:Y

OFFICIAL USE ONLY Casentle: Special Project NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Docllnk: l:l Date: 12/18/2015 Note

Title:

~ Summary Note: info moved to quarterly report Read Authorization: [Monitor), [All)

Allow Other Editors: Edit Authorization:

[Management),*,(b r,t~)(~7)""

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Prepared by: 2/13/2015 Case Tltte: Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC- Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classlfication:

Origination Doclink: '.)

Date: 12/11/2015 Note

Title:

(b)(?)(C) Summary Note: moved to quarterly report Read Authorization: [Monitor], [All]

Allow Other Editors:

I OFFICIAL USE ONIL.Y

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(?)(C) !12104/2015 Case Tltle: Special Project: NRC Case Number: C 13 027

-Regulatory Oversight Program Office: NRC

• Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: l~

Date: 12/04/2015 Note

Title:

~Summary Note: ~ moved to case file Read Authorizatlon: (Monitor), [All)

Allow Other Editors: Edit Aulhorizatl_..,..

on....,: = ,. .,

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OFFICIAL USE ONLY ChronNote Prepared by: !(b)(7)(C) I12/03/l0/5 Case

Title:

,Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: j Date: 12/03/2015 (b)(7)(C), (b)(7)(0) l(b)(7)(E)

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[Management),(b )(7)(C)

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OFFICIAL USE ONLY ChronNote Prepared by:l(b )(7)(C) 11.2/02/2015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC

• Entire Fiscal Year: 201 3 Team: *AIGI Primary Proactive Initiative Classification :

Origination Doclink: fj Date: 12/02/2015 Note

Title:

P BLANCH - IP LTR Note: info moved to case file r b)(?)(E)

Read Authorization: [Monitor], [Alij

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Edit Authortza~g

• Mana ement},} )(7)(C)

(b)(?)(C) NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(?)(C) 1 12/0212015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 201 3 Team: AIGI Primary Proactive Initiative Classification:

Origination Docllnk: j Date: 12/02/2015 Note

Title:

Proactive Initiative - Callaway Note: This proactive review resulted in no actions.

As a proactive *mItIat1ve,.__

_ ___, and OIG Engineenng (b)(?)(C) . . Intern has foIIowed the unexpected trip at Callaway Nuclear Power Plant on August 11 , 2015, due to a wiring error for the main transformer. While responding to this trip, the Licensee found that one of the two safety-related, motor-driven auxiliary feedwater flow control valve could not perform its safety function. It was also determined that these control valves have a history of inoperability and have exceeded technical specifications in the past. Attached is relevant information to date:

Im Ea J J- J-Callaway_lR2015003.pdf

...J-. Callaway_IR2014005.pdf I

Callaway_event_notification_51 308.PNG Callaway_LER_Oct 1 201 5_Aux FP Controls.pdf Elll'-

J-Callaway_LER_Oct 12 2015_Aux FP Controls.pdf m-1 MTF_Case 13 027_ Callaway_Aux FP_Nov 2015.docx Read Authorization: [Monitor], [Alij Allow Other Editors:

OFFICIAL USE ONLY

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C_) _ _ _ _1REVIEW CASE FILE NUMBER 13 027 NRC Office of the Inspector General PAGE 1 OF 4 PAGES DETAILS Memorandum to File

Subject:

As a proactive initiative,~and OIG Engineering Intern has followed the unexpected trip at Callaway Nuclear Power Plant on August 11, 2015, due to a wiring error for the main transformer.

While responding to this trip, the Licensee found that one of the two safety-related, motor-driven auxiliary feedwater flow control valve could not perform its safety function . It was also determined that these control valves have a history of inoperability and have exceeded technical specifications in the past.

OIG learned that NRC completed a "post maintenance inspection of one of the motor-driven auxiliary feedwater flow control valve in December 2014 and reported no findings.

Below is a summary of documentary information reviewed to date:

Timeline Oct. 2014 -MD 8.3 - Maintenance performed on ALHVOOll. The setting of a valve potentiometer was not verified following maintenance.

October 23, 2014 - MD 8.3- The bridge rectifier was modified on a control card for valve ALHV0007 November 15, 2014-MD 8.3- The bridge rectifier was modified on a control card for Valve ALHVOOOS.

December 3, 2014 - MD 8.3 -Valve ALHVOOOS did not close following a plant trip because the bridge rectifier failed.

December 3, 2014 - MD 8.3 -The licensee replaced the ALHVOOOS Control card with another having a similarly modified bridge rectifier.

December 4, 2014- NRC inspection 2014005, Included post-maintenance inspection of motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs July 23, 2015 -MD 8.3 -ALHVOOll closed and failed to reopen following a reactor scram.

August 11, 2015- MD 8.3 - Valve ALHV0007 closed following a plant trip but did not open upon demand because the bridge rectifier failed.

THIS OOCUMHll IS HE PROf>cRTV Of Tl!E U S l+\ICLEAA. REGULATORY C0"1MISUIN. Df'FICE Of l tiE IN$Plai:TOP. GEJIIEAAL IOIGt 11 OJl)jfD TO ANOfHER AGENCV IT AND ITSCIJNTENrs A Rf NOT TO 6E REl'RODUCf.DCIR [IIST1H!IIJ IEU nUTSlOE IH," ~ECEIVIN" AllENCV WITHOUT OIG'I pe,1-.1ss. JN OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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CASE FILE NUMBER 13 027 NRC Office of the Inspector General PAGE 2 OF 4 PAGES I

August 11, 2015 - MD 8.3- The control card for ALHV000S was replaced with a properly modified card.

Sept 19 - NRC special inspection, non-cited violation for declaring the system operable without fully understanding the failure mechanism.

Summary of 2014 Card failure, ALHV000S

- In October and November 2014, two auxiliary feedwater valves were fitted w ith new control valve control cards. These cards were reverse engineered by a vendor (Nuclear Logistics), from the existing cards. The bridge rectifiers used in the original cards were unavailable due to obsolescence, so new ones were made and used.

- A Plant trip caused valve ALHV000S (same component type as the 2015 card failure, ALHV0007) to fail, one month after installation of the modified cards. The bridge rectifier was found to be damaged, and the card was determined to have failed due to an "infant mortality" issue. The failed card was replaced by an identical card.

- Post-ma intenance t esting of the replaced card, as well as surveillance testing of both cards until the 2015 plant trip did not expose any failure conditions to the cards.

- NRC inspection 2014005 was conducted and included post-maintenance inspection of motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs. No findings were identified.

• In response to the 2014 card failure, Nuclear Logistics designed new modified bridge rectifiers w ith increased amperage ratings. for the cards, which were installed for both auxillary feedwater valves, but the ALHV000S and 0007 cards were allowed to remain in use until the next refueling cycle in 2016.

THl'l oar *MEN T IS THE PROPEi! rr OF THE U-~ NIJClEII"' RE(;VlATORY C:0"1MISSION, a. ncE OF I HE lll&n-c-oiJ Gl:NERAI !010 If <ANEJ) TO ANOTHER AGENc,* "-"ND 1n CONTENTS I.RE NOTTO BE REPROOUC£D .,p OISTRIBVIE[)

CJIJ1 S10E TH= P.fCEIVING AGENCY WI THOUT ou:;** PEAMl~Sk>N, OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

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1) _ _ _ _____,I REVIEW CASE FILE NUMBER 13 027 NRC Office of the Inspector General PAGE 3 OF 4 PAGES I

Summary of 2015 Card Failure. ALHV0007

- On August 11, 2015, a grid disturbance caused a turbine and reactor trip at Callaway plant and initiated Auxiliary Feedwater System actuations. All systems involved in the reactor trip initially responded as expected. Approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following the trip, while attempting to transfer to the motor-driven auxiliary feedwater pumps, flow control valve ALHV0007, would not respond to "open" demand signals from the control room.

- The bridge rectifier was again found to be damaged.

- According to the licensee, the operating temperatures affected performance of the cards, and placed them in unexpected operating conditions

- New cards from Nuclear Logistics with the increased amperage rating rectifiers were i1nstalled for both ALHV000S and 0007.

- NRC conducted a special inspection on Sept 19, and issued a non-cited violation for declaring the system operable without fully understanding the failure mechanism. A partial systems walkdown was performed, no findings were identified.

NRC Inspection report data:

1. Inspection Report 2014005; P.15, post-maintenance inspection scope

a. December 4, 2014, motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs, Job 14006195. The inspectors reviewed licensing- and design-basis documents for the structures, systems, and components and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, and components. These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111 .1 9.

b. Findings: No findings were identified.

2. Special inspection Report 2015003 Cornerstone: Mitigating Systems. Green.

THl3 DOCUMENT '8 THE PROPERTY OF TliE U.~. NUCLEAR REGULATORY COMMISSION, ~FFICE OF THE INSPECTOR GENERAL (OIGJ IF LOA.NED TO ANOTHER AGEN"' IT ANO ITS CONTENTS ARE NOT TO ee REPRODUCED OR DISTRISIJTEO OUTSIDE THE RECEIVING AGENC't' WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONI.Y-OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Re,vised: December 2014

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The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "lnstructions1 Procedures, and Drawings," for the licensee's failure to follow their operability determination procedure.

Specifically, when an auxiliary feedwater control valve failed to operate from the main control room, the licensee fa iled to evaluate the operability of the component In accordance with Procedure ODP-ZZ-00001, Addendum 15, "Operability and Functionality Determinations." The immediate corrective action taken by the licensee was to evaluate the operability of the flow control valve. After determining that the equipment was inoperable, the licensee entered the required technical specification condition and performed the required technical specification actions. The licensee entered this issue into their corrective action program as Callaway Action Request 201502708.

This performance deficiency is more than minor and, therefore, a finding, because, if left uncorrected, it has the potential to lead to a more significant safety concern if safety-related systems are not properly evaluated for operability. The finding affects the Mitigating System Cornerstone because the performance deficiency is related to the auxiliary feedwater system's ability to conduct short-term decay heat removal.

Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions,"

the finding was determined to be of very low safety significance because it did not affect system design, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. This finding has a cross-cutting aspect of challenge the unknown in the human performance cross-cutting area because the licensee did not stop when faced with uncertain conditions. Specifically, rather than declaring the system inoperable and allowing the process to evaluate the condition, the licensee declared the system operable without fully understanding the failure mechanism [H.11]. (Section lRlS)

Attached Documents:

1. Licensee Event Notification

2. Licensee Event Report (LER), October 1, 2015

3. Licensee Event Report (LER), October 12, 2015 (b)(7)(C)

NAME \ SIGNATURE DATE 12/1/2015 REVIEWER NAME\ SIGNATURE l(b)(7)(C) I DATE THIS DOCUMENT IS THE PROPERTY OF THE u s NUCLEAR REGULATORY COMMISSION, OFFICE OF me INSPECTOR GENERAL (OIG)

IF LOANED TO ANOTHER AGE'NCV, IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: December 2014

OFFICIAL USE ONLY ChronNote Preparedby: (b)(7)(C) 12/0111015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office. NRC- Entire Fiscal Year: 2013 Team: AIGI Prtmary Proactive Initiative Classification:

Origination Doclink: 1 ~

Date: 12/01/2015 Note Trtle: Follow-up LOCHBAUM Note: On 12/1/2015, LOCH BAUM provided the following information:

1. The results of his study for "merchant" versus "regulated" plants. (b)(?)( l evlewed his study and determined, "that "utility owned" had 3 occurrences for quarters 1n co umn 3, 4 or 5, versus "wholesale commodity owned" had 38. Even though the number of ownerships was 5 versus 7, it's still a pretty biA discrepancy."

Entergy Built vs Bought.jpg 2 . From: Dave Lochbaum [maItto:Dlochbaum(iilucsu~a.o,g)

Sent: Tuesda December 01, 2015 9:22 AM To: (b )(7)(C)

SubJec : x erna _ ender] RE: Feedback Hel1o E'.]

Here's the email I sent t~ (b)(?)(C) Iof Pilgrim Watch.~ emailed me to question whether it might be feasib le to have GAO take over the cancer study that NRC declined to fund.

~ orwarded the email to others who work on radiation health issues. I've heard that group

~ nsulted attomey l(b)(7)(C) !to see if there's a legal option to pursue. The options I heard about involved fi ling a petition with the Commission seeking immediate suspension of issuing oew and renewed operating licenses based on the prima facie evidence of the agency lacking valid information about health consequences from routine releases and using the same argument to seek a court injunction against the agency issuing reactor operating licenses/relicenses.

Attached is the table showing the results from the study of Entergy's reactors. I developed a spreadsheet showing the ROP Action Matrix Column placements for each Entergy reactor over the first 56 quarters of the ROP. I then extracted these statistics from that data.

OFFICIAL USE ONLY

OFFICIAL USE ONLY The Average Column Placement column shows the average column each reactor was in during those 56 quarters. I assigned a 1 for being in Column 1, 2 for being in Column 2, etc. The results show that Entergy's reactors in regulated states perform better than its merchant reactors. The average owned reactor scored I.I 7. The average merchant reactor scored 1.30.

To me, the results could be explained either of two plausible ways. First, one could contend that Entergy does not provide the budget necessary for its merchant reactors to perform as well as its owned reactors because it must compete in de-regulated electricity markets. Second, one could contend that Entergy bought reactors having "value" (i.e., cheap on the market). A top performing reactor commanded a high price, which Entergy was not willing to pay. A poor performing reactor was relatively less expensive and more attractive to Entergy. Entergy's merchant reactor acquisitions had pre-existing performance problems that the company has been unable or slow to remedy.

J don't know which is the more likely reason. I may submit a letter to NRR providing the data and suggesting they might want to probe the situation to see if merchant reactors are underperforming non-merchant reactors and, if so, why.

Thanks, Dave Locbbaum ucs

. l/b)(7)(C)

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Ematl response to ,___ _ ___,

Hello l~~r) I Even yesterday's GAO would likely not be able to discern the real reason the NRC canceled the study. NRC would control whom GAO talks with, and that whom will tow the party line or risk becoming a what.

There might be some mileage in turning NRC"s reasons arow1d against them. They contend tbat jt would take $8 million and many more years to complete the NAS study, despite NAs having already spent some years at it.

Let's stipulate this is all true and accurate.

So, the NRC is many years away from knowing whether routine releases have adverse consequences. How can they extend the operating lifetimes of existing reactors or license new reactors given uncertainty about this vital public health question?

Clearly, the scope of work is not merely updating the early 1990s study to account for population differences, etc. That it would take so much time and effort to complete the ongoing study is strong prima facie evidence that the existing study is fundamentally deficient.

Again, if the evaluation of record is so deficient and out-dated that it would take another $8 million and many more years to fix it,how can the NRC use its results to make decisions about OFFICIAL USE ONLY

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Even at NRC's low-ball value of $3 per human (i.e., non-NRC) life, the study would only have to save three lives to be cost-justified.

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Origination Docllnk: -1 Date: 11 /19/2015 Note

Title:

Meeting with Dave Lochbaum (b)(?)(C)

Note: On Nov 19, 2015, Dave Lochbaum was at HQs for public meetings.

and Dave met and discussed:

1. Lochbaum's concern with Green Piece's security FOIA. He believes NRC has sent mixed messages and is working with !(b)(7)(C) ~ nd (b)(7)(C) to fix .

2. Lochbaum attended a Project AIM briefing. He ha no comment.

3. Lochbaum was surprised the Commission voted against the "Cummulative Effect of Regulation" that Licensees/Industry proposed.

4. Lochbaum discussed a concern - that he and other special interest groups are currently research in - is the NRC cancelling phase II of the NAS cancer study. He mentioned that (b)(7)(C) is considering submitting a 2.206. The NRC is saying the project was cancelled due to funding but Lochbaum and other special interest grou s are wondering if it was cancelled due to "bad news." Lochbaum agreed to inform (b)(l)(C) once more information is available.

5. Lochbaum discussed a study he conducted of Enter ' s in the "merchant market" versus the "regulated market." He will send analysis to (bJ(7l(C)

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(b)(7)

Note Tit!e: ~ I (D) rojec1 Note: c.::.:Jan met to discuss this project. The following activities were accomplished: (1) Reviewed the results from the 2015 ROP study and discussed how to update. Also discussed Including "

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Note:

Cooper Allegati (b)(i')(C) l(b)(7)(C) b Today, 8/3/15,_..,,..,._spoke with .__...,........,.--. n the phone regarding his July 30th conversation with Region IV. Below are my notes from the conversation .

. (b ( )(

• Region IV told calculation the*'"nm:n:m"TTI' hat NRG was going to perform an on-site inspection of the 15.

• Region IV is sending (b)(7)(C) (sp??).

• Region IV mentione review.

ot have any specific technical issues after they did their

• NRR said plastic analysis was an acceptable methodology. HoweverJ(b)(7)(C) lbelieves nalysis is not.

• commented that he believes that Cooper just needs to install "turbine blow out which is an inexp*ensive fix ~specjaUy sjnce r e design calculations do not meet the UFSAR design basis. (i.e. hopeful! _(b)(?)(C) _will help determine if the calculations are adequate.)

(b)(7)

(CJ remindedl(b)(?)(C) ~hat OIG is just "watching" because Region IV is in the allegation process.

Prior to the call, (b)(7J(CJ reviewed the technical information NRR supplied to the Region (see attached.) Basica ly, they found an error in the plastic analysis calculations. The error would cause the Licensee to be outside of the design basis. l(b)(?)(C) determine that. .

I review should

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St. Lucie MSIV Operating Experience Report Note: This document is NON public.

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Questions for Region II meeting regarding seismic allegation for Chrystal River rwJ

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Case 15-007 Status for Commission Vote on SECY Note: On ,h,oe 1 201~, LOCHBAUM forwarded his e-mail correspondence with

)(b)(7)(C) l to !(b)(?)(C) which stated that , "The Commission is near finished voting on the paper. My best guess is that this is fairly close to being completed. Regarding the availability of the paper, I am checking. I would have anticipated that it would have been made available by now.

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Title:

Phone conversation with Paul Blanch Note: Paul explained his continued frustration with NRC decisions related to the Indian Point gas line project called AIM. He forwarded state congressional testimony. (see attached file.) Paul is awaiting a response to his 2.206 Petition and hasn't decided if/what he will request for an OIG investigation. He also has pursued other sources to express his safety concern to include ACRS. He hasn't requested (to date) an OIG investigation because he mentioned that OIG take~ too long and his concern is time dependent.

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(b)(7)(C) NRC OFFICIAL USE ONLY

l.._l(b..._  :) _ _ _ _____.1 REVIEW l )(.7_)..._)(C....

CASE FILE NUMBER NRC Office of the Inspector General PAGE 1 OF 2 PAGES DETAILS Memorandum to File Summary of Contact On Friday, March 13, 2015, David LOCH BAUM met with r )(?)(C) land S (b)(?)(C) lat the OIG offices in headquarters to discuss LOCHBAUM's Novem er 2014 letter to the Commission. In general, LOCHBAUM's letter to the Commission addressed his recent FOIA request for fire protection license amendments and UFSARS. To date, LOCHBAUM has not received a response to his letter However, he met with NRC management and provided the following up date to OIG:

• LOCHBAUM met with l(b)(?)(C) l and l(b)(?)(Cl I. They shared with LOC HBAUM that the staff has drafted a SECY in response to the concerns in discussed in his November 2014 letter. Although LOCHBAUfyl could not read the SECY, he was told his concerns with "blanket withh ldina" of UFSARs, Fire Protection LARS, and Emergency Planning will be addressed. (b)(?)(C) !mentioned that the staff SECY's proposed a path forward for making documen s puouc.

• Based on these discussions, LOCHBAUM agreed to withdraw his recent FOIA in which he requested all UFSARS. LOCHBAUM was told that this FOIA request would be 500 million pages. LOCHBAUM was also told that the staff will implement a "quick response" to a request by the public for a UFSAR, Fire Protection LAR or Emergency Planning, while the SECY is being reviewed by the Commission.

• LOCHBAUM's concerns regarding the past informa1ion being withheld from the public (i.e.

from 2007 to present) "might or "might nor be addressed in the SECY. Although LOCHBAUM initially requested OIG to investigate the "past withholding of information, he agreed to put the OIG request on hold until the Commission reviewed and provided the SRM to the staff.

• LOCHBAUM also met with Commissioner Baran and Chairman Burns and LOCHBAUM said U1e SRM could address the "past" and present." LOCHBAUM expects a letter from the Commission and the SRM direction to be given soon.

• If the "past" concern for withholding information is not addressed in the SRM, LOCHBAUM believes his next steps, on behalf of Union of Concerned Scientist, will be a letter to the NRC.

LOCHBAUM agreed to keep OIG informed of NRC's actions regarding his concerns.

There were no action items for OIG from this meetino.

I I h \(7\/f 'l DATE

\UJ\I )\L,)

3/13/15 REVIEWER NAME I SIGNATURe (b)(7)(C)

"THIS OOClJMENT IS "THE PROPERTY OF THE U,S. NUCLEAR R~~~RY COMMISSION, OFFICE OF THE INSPECTOR GENERAL iOIGJ IF LOANED TO ANOtHER AGENCY. IT ANO ITS CON~ ARE NOT TO BE REPRODUCED OR OISTRIBUTEO OUTSIDE THE RECE'l\/lNG AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIGIAIGI Form 724 Revised: December2014

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Date: 03/13/2015 Note

Title:

~ orking Plan for l(b)(7)(A)

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Origination Doclink: ij Date: 03/12/2015 9-l -I Cooper_NRC close-out ltr_Feb 25 2015_ 11091 Letter - Response after closure october 2014.docx Read Authorization: [Monitor], (All]

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Origination Doclink: ["1 Date: 11/05/2014 Note

Title:

S oke with (b)(?)(C)

Note: (b)(?)(C) Is a ega I0n and it's correlated to A 15 07572. (12/1/14 comment)

He talked about his entire whistle b°lowing activities at Vermont Yankee . He sent me e-mails about previous 2.206s he filed and his blog. He explained his current concern with Milestone's 50.59. "Is it easier to ask for forgiveness?" 50.59 problems and UFSAR only get discovered by accidents. Whistle blowers are out gunned with federal lawyers. There would be more whistle blowers if the protection was better. Discussed Milestone feed-water isolation valve (2007) .... actuator not properly sized ....was degraded ....once they told NRC ... .in Nov 2nd entry....NRC gave them 3 more cycles to fix. Was a tech spec violated? Was it degraded?

What are your facts? Don't test? Broken equipment seems to have more and more equipment problems. I sent him the link to the OIG annual plan and referenced our website for further information on our roles and responsibilities .

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10/24/2014

.,i;;.µ,~;..i..uiJ.ll.t;,rsation with._

(b)(7)(C) I l _ _ _ _____,- Special Interest Group 7

Note: (bl( l(C) called me, after contacting AIGI, who provided my phone the feed pump.

comparison to

~gl<g number. He has concerns w 1 h Millstone Special Inspection and the 50.59 "white" finding for N S.

I is going to e-mail a summary of his concerns and include a Read Authorization: [Monitor], [All)

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classlficatlon :

Origination Doclink: lj Date: 10/15/2014 Note

Title:

On-going communication with Paul Blanch Note: Attached are e-mail communications with Paul Blanch .

Ea-

)... Q I P Blanch e-mail_Oct *15 2014.PNG 20141015 final signed IP 2 206 petition on AIM project .pdf m:m-10 CFR 50 59 Entergy's_R,eport_ to_the_NRC_re_AIM_ project_Saf,ety.pdf Read Authorization: [Monitor], [All]

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OFFICIAL USE ONLY Allegation Report Prepared by: l(b)(?)(C) I 10//0/1013 Case

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Special Project NRC Case Number* C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

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Allegation Report Re ort Date:

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MTF Allegation NCLab caset3-7292[ _ _ Jdocx review my c anges an ma e any necessary changes.

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OFFICIAL USE ONLY Comment Prepared by: jcb){Z)(C) j 10/29/2013 Case

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: *NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink : LI (b)(7)(C)

Comment I Question RC 10/29/2013 09:13:37 AM Add Reply Read Authorization: (Monitor], (All]

Status: Open Request Revilew: Edit Authorization:

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j(b)(7)(C)

Closed By1.__ ___, 10/29/2013 09:13:50 AM l(b)(? )(C ) ~ RC, OFFICIAL USE ONLY

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Special Project: NRC Case Number; C 13 027

,Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: 'AIGI Primary Proactive Initiative Classification:

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Closed to File Memo Case 14 027 Report Date: 11/13/2015 fy1oved to case file j<b)(7)(E)

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Special Project: NRC Case Number: C 13 027 Regulato ry Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: I)

Report TiUe: Closed to File Memo, Case 13 042 Report Date: 08/21/2015 Moved to case file l(b)(7)(E) Read Authorization: (Monitor], [All]

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7) C .___ ___.

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Level 1 Approval:

Level 2 Approval*

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Project Closure Memo Prepared by: !(b)(?)(C) I 06/28/2017 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: A IGI Primary Proactive Initiative Classification:

Origination Doclink: rl Report

Title:

Project Closure Memo Report Date :

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Case 13 027_CTF Memo.pdf (b""""

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")"(""' Dale 07/31/2017 01 :20 PM 06/28/2017 09:1 5 AM

_ncurred by Name l(b)(?)(C) co I 08/04/2017 03:22 PM Dale r )(7)(E)

Read Authorlzadon: [Monitor], [All]

Allow Other Editors: Edit _

Authorization:

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Level 1 ApprovtJI:

Level 2 Approval: Approved 08/04/2017 03:22:40 PM OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memorandum ofInterview Prepared by: !(b)(7)(C) ! 10/14/2015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: .:'.)

7 Conducted By: l(b-)(- )(-C)_ __,INRC,l(b)(?)(C)

Person Being Interviewed : _ .

Date of Interview: 10/07/2015 Location of Interview:

Purpose of Interview:

Narrative of Interview:

Additional Information :

Request Review:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memorandum ofInterview Prepared by: i(b)(7)(C) I 10/14/20/5 Case

Title:

Special Project: NRC Case Number: C 13 027

• Regulatory Oversight Origination Doclink : Cl Conducted By: ..,,.

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• Date of Interview: 09/1 Location of Interview:

Purpose of Interview:

Narrative of Interview:

Additional Information :

Request Review:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memorandum ofInterview Prepared by: i(b)(7)(C) I 10/14/2015 Case Trtle: Special Project: NRC Case Number : C 13 027 Regulatory Oversight Origination Docllnk: [.)

Cond uctedBy: l_

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Person Being Interviewed :  ;:;;:l (b:;::;;

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c)=::::::!......,I Date of Interview: 09/15/2015 Location of Interview:

Purpose of Interview:

Narrative of Interview :

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OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memorandum ofInterview Prepared by: i(b)(?)(C) I 10/14/20/5 Case

Title:

Special Project: NRC Case Number* C 13 027 Regulatory Oversight Origination Doclink: [)

Conducted By: (b)(?)(C) l(b_l<?_)<c_)_

NRc,.... __,~ Rc.l<b)(?)<c)

Person Being Interviewed : (b)(?)(C)

Date of Interview: 09/14/2015 Location of Interview:

Purpose of Interview:

Narrative of Interview:

Addition al lnfonnatlon:

Request Review:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memorandum ofInterview Prepared by* l(b)(7)(C) 110/14/20/5 Case

Title:

Special Proj ect: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: )

Conducted By: (b)(7)(C) NRC,l(b)(?)(C)

Person Being Interviewed : (b)(7)(C)

Date of Interview: 09/14/2015 Location of Interview:

Purpose of Interview:

Narrative of Interview:

Additional Information :

Request Review:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memorandum ofInterview Prepared by: i(b)(?)(C) I 10/14/2015 Case

Title:

Special Project: NRC Case Number: C 13 027

,Regulatory Oversight Origination Docllnk: l:J Conducted By: m(~b)ri )("'C)____........""'1..,.....---...J RC, l(b)(?)(C)

(?ii"i Person Being Interviewed: (b)(7)(C)

Date of Interview: 09/14/2015 Location of Interview:

Purpose of Interview:

Narrative of Interview:

Additional lnfonnatlon:

Request Review:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memoran ___ _lnterview Prepared by. 08/20/1015 Case Tide: Special Proj ect: NRC Case Number: C 13 027

,Regulatory Oversight Origination Docilnk:

(b)(7)(C) 7 Conducted By: NRC, ... cc_) _ __,,NRG l(b-)(_)_

Person Being Interviewed:

Date of Interview: 08/ 19/2015 Location of Interview: OIG Purpose of Interview:

witness Narrative of Interview:

~ (b)(7) ~ . -

MOl ~ ocx (C) em;ill.pdf (b)(?)(C) pdf Additional Information:

_____________c_oncurred by Name Date l(b)(7)(C)  ! 08/25/2015 07:40 AM Request Review:

OFFICIAL USE ONLY 1

l(b)(7)(C) l(b)(7)(C)

From:

Sent:

To:

Subject:

Attachments:

Good morning (b)(l J(C)

I just wanted to con irm at OIG received the attached email. Also, because I need to address the !(b)(?)(E)

!(b}(?)(E) 11was going to place a copy of the attached email in ADAMS, as publicly available but w,th our name redacted, to be consistent with how I handled the transcripts from the teleconference with the (b)(7)(E) last year.

AGENT'S INVESTIGATIVE REPORT I

CASE FILE NUMBER l(b)(?)(E) 13 027, NRC Office of the Inspector General PAGE 1 OF 1 PAGES I

DETAILS Memorandum of Interview

SUBJECT:

INTERVIEW OFl(b)(?)(C)

I On A11nw::t 19 ?015 l(b)(?)(C) I (b)(?)(C) I Nuclear Reactor Regulation (NRR), was interviewed by Special Agentl(b)(?)(C) I (bJ(7)(\.,J I Office of lnsoector General (OIG), Nuclear Reaulatory Commission (NRC) and~

(bJ(?J(CJ I OIG, NRC, per l(bJ(?)(C) !request regarding a petition e I ea on July 18, 2014.

I (b)(?J(Cl informed OIG that she was going to place the attached document into ADAMS, as publically ava11aoIe and requested OIG's concurrence.

The document is attached:

AGENT NAME \ SIGNATURE DATE r )(7)(C) 8/19/2015 I

TEAM LEADER NAME I SIGNATURE DATE l(b)(?)(C)

I THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISION OFFICE OF THE. INSPECTOR GEN[RAL (NIIC OIGI IF LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIOf THE RECEIVING AGENCY WITHOUT THE PERMISSION OF THE NRC: OIG.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Form 701 Revised: Nov 2013

(b)(?)(A),(b)(7)( C)

OFFICIAL USE ONLY Memorandum ofInterview Prepared by: i(b)(?)(C) I 10/1412015 Case

Title:

Special Proj ect: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: CJ Conducted By:  !(b)(7)(C) ~NRc,l(b)(7)(C) ~RC Person Being Interviewed :  !(b)(?)(C) I ...._____,

Date of Interview: 07/16/201 5 Location of Interview:

Purpose of Interview:

Narrative of Interview :

Additional Infonnatlon:

Request Review:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY ChronNote P,*epared by: i!b)(])(C\ I 11/15/2013 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: ,NRC - Entire Fiscal Year: 2013 Team: ,AIGI Primary Proactive Initiative Classification:

Origination Doclink: 0 Date: 11/15/2013 Note

Title:

Revised Summary of Region Ill discussion regarding Palisades Note: info moved to case file Read Authorization: [Monitor], [All]

Allow Other Editors:

OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(?)(G) IJJ/1412013 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: 1NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: I)

Date: 11/14/2013 Note

Title:

Summary of Region Ill discussion with 01 regarding Palisades Note: Corrected editorial errors in document and re-submitted on 11 /15/13 Read Authorization: [Monitor], [All]

Allow Other Editors: Edit AuthorizaUg

• 111,.*:.....,,.,......,

Mana ement) (b)(l )(C)

(b)(7)(C) NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(?)(C) !JOl29110/3 Case

Title:

.Special Project: NRC Case Number : C 13 027 Regulatory Oversight Program Office: NRC

• Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: I J Date: 10/29/2013 Note

Title:

info moved to case file Note:

Read Authorization : [Monitor), (All)

Allow Other Editors: Edit Authorization :

(Management],""!(b..,..,)(""7).,..

(C,.,...

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l(b)(7)(C) ~ RC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: !(b){?)(C) ! /0/2512013 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Doclink: I)

Date: 10/25/2013 Note

Title:

Public Interest Group - conference call If Note: MTF_Public Interest Groups_Oct 25 phone conversatlon.docx r )(7)(E)

Read Authorization: [Monitor], (All)

Allow Other Editors: Edit Authorlzati~

Mana ement],~

(b)(7)(C) NRC OFFICIAL USE ONLY

l_

(b_ 7)_(c_:i _ _ _ ____,I REVIEW i)(...,.

CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 1 OF 2 PAGES DETAILS Memorandum to File Summary of Contact Notes from October 24, 2013, conference call with Special Interest Group Members: Dave LOCHBAUM, l~~r) l(b)(7)(C) H(b)(7)(C) ~ andl(b)(?)(C) 1*

I The subject of the ,conference call was to discuss the 10 CFR 50.109, back fit cost/benefit analysis, for the Mark I and II BWRs hardened vents and provide supplemental information to the 2.206 Petition to address potential misconduct or inappropriate implementation of policies/procedures by the staff.

CONCLUSION:

LOCH BAUM will submit a letter to OIG requesting investigation of the cost/benefit analysis for the Mark I and II BWRs hardened vents and include specific areas of concern related to the NRC's misconduct.

DISCUSSION:

(b)(?)(C) I stated that SECY 2012-0157 was well developed with the staff's cost/benefit and the staff did address the uncertainties and associated risk. However, several Commissioners "over-ruled" the staff and decided to discount the qualitative uncertainties.

(b)(?)(C) !provided the name of l (b)(?)(C) land l(b)(?)(C) r ho were proponents of the quantitative and qualitative analyses.

(b)(?)(C) lcited the Chairman's notation vote that stated the staff used current guidance and uncertainties were a primary concern.

(b)(?)(C) !discussed the GEH retrofits already available and being installed in the 14 Japanese BWRs.

LOCHBAUM discussed 3 areas of concern related to the cost/benefit and believes them "cherry-picked" instead of following guidance to include all possible scenarios. In summary: (1) the staff assumed 100%

completion of lessons learned (i.e. emergency planning), (2) did not include economical loss to the public such as houses, etc., and (3) the cost/benefit was based on a "desired solution" so someone worked backwards to get that answer.

~OCHBAUM provided an example of an adequate cost/benefit which was the spent fuel pool instrumentation.

!(b)(?)(C) !had 2 areas of concern. His first was the information wrii tten in the February 20, 2013 USB financial report that states, "qualitative analysis..." basically was ignored. And second, the statement in the USB report THIS OOC\JM!.Nl IS ltiE PROP(tHY OF lHl NJtC. IF ~OANEO TO ANOTHER AGENCY IT AND ITS CONltll/TS ARE NOTTO BE f\ff>ROOUCFD OR DISfRISUTtD OUfSltlt THt ftHt1VtNG ll<>LNCY WI IHOUI l Hl P("MISSION or HI( on IC[ or me INWh. Tl)!{ GlN [Ml OFFICIAL USE ONLY - OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: June 2013

1.._

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<C_._:) _ _ _ _____.I REVIEW CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 2 OF 2 PAGES rega,rding "fragile economics ... added stress on plants..." swayed NRC management's decision.

(b)(?)(C) aid it's just like the situation with Davis Besse" as reported in the OIG report, that management is uumping staff' s determination.

(b)(?)(C) Istated that outdated models are being used for the cost/benefit analysis. She believes the statt 1s aware of ~his fact but chose to continue to use them. This includes using pre-Fukushima data instead of post-Fukushima data.

(b)(?)(C)

NAME I SIGNATURE REVIEWER NAME I SIGNATURE DATE (b)(?)(C)

October 25, 2013 THIS DOCUMENT IS THE PROPERTY OF THE NRC. If LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT THE PERMISSION OF THE OFFICE OF THE INSPECTOR GENERAL OFFICIAL USE ONL't- OIG INVESTIGATION INFORMATION OIG/AIGI Fonn 724 Revised: June 2013

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(7)(C) ! 10122/2013 Case

Title:

Special Project: NRC Case Number : C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: [J Date: 10/22/2013 Note

Title:

Lochbaum phone conversation - Palisades post Chairman ltr Note: info moved to case file Read Authofizatlon: (Monitor), (All)

Allow Other Editors: Edit Authoriza~ -

Mana emenl), (b)(7)

(b)(?)(C) NRC C OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: i(bl(7)(C) I 10/21/2013 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proact ive Initiative Classification :

Origination Doclink: Q Date: 10/21 /2013 Note

Title:

NRC Reviewer's Validation of Information Ell

}-

Note: 52FedReg_10CFR50.9_NRC Review Summary for OIG question_Oct 2013.pdf w

-- (b)(7)(C)

NRC Reviewers_evaluation guidance summary_Oct 2013.dotx Read Authorization: [Monitor], [Alij I Allow Olher Editors: Edtt Authoriza11,1w;i,;._ _

Mana ement], (b)(7)(C)

(b)(?)(C) RC OFFICIAL USE ONLY

r----------IREVIEW b)(7)(C)

CASE FILE NUMBER 13-027 NRC Office of the Inspector Genera l PAGE 1 OF 3 PAGES DETAILS Memorandum to File Review of Regulatory Documents 1

This document summarizes NRC guidelines and regulations supporting the answer to the comment, 'Why can't NRC reviewers validate the information they review and evaluate?"

Summary The answer to this comment is twofold. First, NRC regulation 10 CFR 50.9 provides the basis for the information provided to NRC reviewers for evaluation. And second, NRC reviewers have procedures that provide specific guidance for requesting additional information from Licensees.

DISCUSSION-REGULATION On December 31, 1987, in Federal Register Notice (FRN), Volume 52, No. 251, the NRC codified 10 CFR 50.2, explaining, "for an applicant's and licensee's obligation to ensure the completeness and accuracy of its communications with the Commission, to maintain accurate records and to report to the NRC information identified by the appllicant or licensees as having a significant implication for the public health and safety or common defense and security. As discussed in the statement of considerations that accompanied the proposed rule, accuracy and forthrightness in communications to the NRC by licensees and applicants for licensees are essential if the NRC is to fulfill its responsibilities to ensure that utilization of radioactive material and the operation of nuclear facilities are consistent with the health and safety of the public and the common defense and security.

Additionally the FRN states, "Several provisions of the Atomic Energy Act highlight the importance of accurate information. Section 186 provides, "Any license may be revoked for any material false statement in the application or any statement of fact required under section 182***. Section 182 provides that, "The Commission may at any time after the filing of the original application, and before the expiration of the license, require further written statements in order to enable the Commission to determine whether the application should be granted or denied or whether a license should be modified or revoked. All applications and statements shall be signed by the applicant or licensee.

Applications for and statements made in connection with, the licensees under section 103 and 104 shall be made under oath or affirmation. The Commission may require any other applications or statements to be made under oath or affirmation ."

Furthermore, "The Commission's expectation of accuracy in communication has not been limited to written information submitted in applications." In a 1976 case, the Commission decision for enforcement was for "omission" of information.

"The Commission decided materiality is to be judged by whether information has a natural tendency or capability to influence an agency decision maker; that knowledge of the falsity of a material statement is not necessary for material false statement under section 186 and that material omission are actionable to the same extent as affirmative material false statements."

rHIS DOCUMENT IS THE PROPERTY OF TllE NRC. IF LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NOT TO BE REPRODUCf.O OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT THE PERMISSION OF THE OFFICE OF THE INSPECTOR GENERAL OFFICIAL ~SE O~b¥ OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: June 2013

________ I l{b)(l)(C)

.__ _. REVIEW CASE FILE NUMBER 13-027 NRC Offi ce of t he Inspector General PAGE 2 OF 3 PAGES

§ 50.9 Completeness and accuracy of information.

(a) Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.

(b) Each applicant or licensee shall notify the Commission of information identified by the applicant or licensee as having for the regulated activity a significant implication for public health and safety or common defense and security. An applicant or licensee violates this paragraph only if the applicant or licensee fails to notify the Commission of information that t he applicant or licensee has identified as having a significant implication for public health and safety or common defense and security. Notification shall be provided to the Administrator of the appropriate Regional Office withi n two working days of identifying the information. This requirement is not applicable to information which is already required to be provided to the Commission by other reporting or updating requi rement s. (52 FR 49372, Dec. 31, 1987)

DISCUSSION - PROCEDURES In NRR OFFICE INSTRUCTION, LIC-101, Revision 4, License Amendment Review Procedures, it states, "The general purpose of this office instruction is to provide guidance, to staff in t he Office of Nuclear Reactor Regulation (NRR), for the processing of license amendment applications consistent with the applicable NRC regulatory requirements. This guidance is applicable to amendments to licenses for operating and decommissioned plants. However, portions of this guidance are also applicable to other licensing actions and activities. For example, the guidance on requests for additional information (RAls) should be utilized in reviewing any licensing action (e.g., exemptions, reliefs, etc.) for which the NRC staff asks the licensee for additional information.

Within LIC-101, in Subsection 4.3 Requests for Additional Information, it states, "RAls serve t he purpose of enabling the staff to obtain all relevant information needed to make a regulatory decision on a license amendment request that is fully informed, technically correct, and legally defensible. RAls are necessary when the information is not included in t he initial submittal, is not contained in any other docketed correspondence, or cannot reasonably be inferred from the information available to the staff. RAls should be directly related to t he applicable regulatory requirements associated with the amendment request. RAls should also be consistent with the plant's licensing basis and applicable codes, standa rds, and guidance (e.g., Regulatory Guides, Standard Review Plan). RAls should not be used as general information requests or as a means to encourage commitments from lice*nsees.

In NRO Handbook, it states, "A Request for Additional Information (RAI) is the NRC's formal means of asking for clarification from an applicant or licensee on the content of a new reactor application or request for licensing action (RLA). During the review of the license application or RLA, the technical reviewer determines if the information supplied by the applicant or licensee is sufficient to make a safety finding. If the submittal does not contain enough information, requires clarification, or requires supplemental information (data, analysis, design detail, etc.), an RAI is issued to the applicant.

THIS DOCUMENT IS THE PROPERTY OF THE NRC. IF LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT THE PERMISSION OF THE OFFICE OF THE INSPECTOR GENERAL OFFICIAL l!ISE ONLY OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: June 2013

TECHNICAL ADVISOR REVIEW CASE FILE NUMBER 13-027 NRC Office of t he Inspector Genera l PAGE 3 OF 3 PAGES (b)(?)(C)

NAME I SIGNATURE REVIEWER NAME I SIGNATURE DATE (b)(?)(C)

I October 21, 2013 THIS DOCUMENT IS THE PROPERTY OF THE NRC. IF LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR 01$TRIBUTEO OUTSIDE THE RECEIVING AGENCY WITHOUT THE PERMISSION OF THE OFFICE OF THE INSPECTOR GENERAL OFFICli!cL USE ONLY=- OIG INVESTIGATION INFORMATION OIG/AI GI Form 724 Revised : June 2013

OFFICIAL USE ONLY ChronNote Prepared by: i(b)(?)(C) I 06/18/2015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: ,AIGI Primary Proactive Initiative Classification:

Origination Docllnk: _3 Date: 06/18/2015 Note

Title:

Case 14-027 ROI St. Lucie H/1 and mtg summary Note: info moved to case file Read Authorization: [Monitor), [All)

Allow Other Editors: Edit Author1za1~ ~ =--

~ ~ent], (b)(7)(C)

~ RC - - - -

OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: i(b)(?)(C) I 06/18/2015 Case litle: Special Project: NRC Case Number : C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: .J Date: 06/18/2015 Note

Title:

Proactive Review - FC

~t~~~~1~:~!~;f~;  ;~~~~2d;~:~

(b)(7)(C)

• * * * * * * * *~~~~:ded(se~-*~tt;~~e~u~::t*( ~ ~ ; ; i ~;:r~:sn~rt~~~

2005-2010, 2011-present), (2) List of components inspected, (3) List of violations from 2000-2015, (4) Chart of Cited Components, (5) Dave LOCHBAUM's article, (6) Binder of LERs (b)(7)(D) Jrom200Q.,,2015, (7) E ]reports docketed from 2000-2015, (8) the combined inspection reports put in Magnum as 3 separate file~d (9) OIG previous case (12-038) involving FC (b)(?)(C)

..... flooding*.Iheagreeduponnextstepsfo ******* Eng Intern are: (1) Take item (2) components and determine if they were cited in any of the O process documents. The 0350 process documents are: Checkoff list, Inspection Reports, and List of Violations. (2) Take Condition Report Numbers from 0350 inspections and see if any of those condition reports were inspected in the 2005-2010 timeframe, (3) Review both of !(b)(7)(C) I transcripts from Case 12-038, (4) Provide feedback on equipment selected for 50.59 and CDBI inspections instead of the 480 Vac breaker, and (5) Identify if the same "sample" was picked for biennial 50.59 and CDBI inspections.

R FCS analysis colors.docx al!

FCS ROP.docx mil Fort Calhoun Analysis.docx

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green analysis 2011-2014 FCS.docx Dynamic Web Site.pdf n green analysis FCS.docx FCS analysis by year.docx IR analysis.doc><. lochbaum.pdf Read Authorization; [Monitor), [Al~

Allow Other Editors: Edit Authorizat1..,

• an...:................

[ManagementJf S)C7)(C) l(b)(7)(C) !NRC OFFICIAL USE ONLY

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OFFICIAL USE ONLY ChronNote Prepared by: !(b)(?)(C) ! 1010711014 Case

Title:

Special Project: NRC Case Number: C 13 027

'Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGt Primary Proactive Initiative Classification :

Origination Doclink: CJ Date: 10/07/2014 Note

Title:

Case 13-7267 review after Close to File Memo was reviewed by !(b)(?)(C) ! Region IV Inspector's Findings for !(w(71/4C~ I Note: Will a ac l F went complete. Currently reviewing transcript with alleger and information in the case file .

Read Authorization: (Monitor], (Alq Allow Other Editors: Edit Au1horizarn

• Mana ement)(b)(7)(C)

(b)(7)(C) NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY Case Tltle: Special Project: NRC ChronNote Prepared by: !(b)(7)(C) ! 10/02/20/4 Case Number: C 13 027 I

Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: *AIGI Primary Proactive Initiative Classification:

Origination Doclink: [J Date: 10/02/2014 Note

Title:

St. Lucie - Allegation regarding inadequate review of Cl's allegation related to diesel generators ~bl 7 C)

Note: spoke with Region II Allegation Coordinator toda 10/2/14)and requested the close-ou etter sent to Cl in early September. He informed (bl(7)(C) hat the Cl submitted new claims regarding the "high level switch" which is used for CONTROL and he said the original was reviewed for the "high, high level switch" which is an ALARM. Therefore, during the week of October 13th, the Region II ARB will discuss the Cl's new allegation.

Read Authorization: [Monitor], [Alij Allow Olher Editors: Edit Authorizatl:,l(,:

on,..,:....,..-

[Management],,(b)(7)(C)

!(b)(7)(C) ~RC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l<b}/7\(C) I 09/30/2014 Case

Title:

Special Project: NRC Case Number: C 13 027 1

Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive initiative Classification:

Origination Doclink: [j Date: 09/30/2014 Note

Title:

MTF for GEH QE TAM summary Note: info moved to case file Read Authorization: [Monitor], [All) 1Allow Other Editors: Edit Authoriza__n *..,.,,.,.,,....

Mana ement), (b)(7)(C)

(b)(7)(C) NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: !(b)(7)(C) ! ()9/lR/2()/4 Case

Title:

Special Project: NRC Case Number* C 13 027 Regulatory Oversight Program Office: NRC

• Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

IDI'-

)..

Origination Docllnk: RE_ Seminar for OIG_OI Personnel.Sept 2014pdf.pdf Date: 09/28/2014 Note

Title:

Technical Training Plan for Special Agents Note: Suggest quarterly technical training From: (b)(7)(C)

Sent: n ay, ep em er 26, 2014 1:56 PM To: McMillan, Joseph

Subject:

1st Q training for SA

Joe, As we discussed, here are my thoughts for 1" quarter training for the SAs.

The first ilearn course that I believe the SA should attend is "Reactor Concepts ." It's the most basic technical course the NRC offers. It's 12 modules and only offered on-line now.

The training center has provided me the CD~ROMS so I could go through the modules with the SA's as a group. I was thinking about setting up 2 hr blocks - starting in October- and going over 2 modules/session. This approach would allow the SA's to ask me questions and would take 6 weeks to complete.

If the SA's chose to take the course on-line, they will have to pass the test to move to the next module. I am getting the test bank from training so it will be an incentive to come with the group since I'll go over the test questions! Thereafter, they will have to go into ilearn and take the test in order to get credit.

I'm still putting the total training plan together and plan to have it done by mid-October.

Please send thoughts .

Thx (b)(7)(C)

OFFICIAL USE ONLY

OFFICIAL USE ONLY

- Read Authorization: [Monitor], [All)

Allow Other Editors:

OFFICIAL USE ONLY

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Title:

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Title:

St. Lucie HI case analysis and power point slide Note: info moved to case file Read Authorization : (Monitor], [All)

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{Management),!(b)(7)(C)  !

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• ~*....,.,,,.......,

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: 'AIGI Primary Proactive Initiative Classification :

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ffi ']

NRC Compilation of the Current licensing Basis Request For Voluntary Participation in PIiot Program (Generic Letter 92-Date: 08/02/2013 Note

Title:

Paul Blanch e-mail regarding Pilot Program for Current Licensing Basis Note: Paul requested in an e-mail dated July 30, 2013, and update to Generic Letter 92-02. The contact folks on the NRC announcement are no Ion er NRC employees.

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• Date: 06/1 4/2013 Note

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Lack of Rigorous Oversight by NRC of Plant Problems at the Fort Calhoun Station Note: Information in case file r )(7)(E) Read Authorization: [Monitor], [All]

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-:..lion

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(Managemen (b)(7)(C)

(b)(7) NRC (C) RC .___ _,

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men (b)(7)(C)

RC, .___ __.

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Title:

Special Project: NRC Case Number: C 13 027

• Regulatory Overs ight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination DocLink : [ ,

(b ( (

Comment I Question NRC 10107/2014 09:46:04 AM Add Reply Read AuthorlzaUon: (Monitor], [All]

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IComment/ Question l<b)(?)(C) INRC 11/22/2013 11 :03:55 AM Deleted document because It was personal notes. Replace with MTF after reading transcripts Add R~ ly Read Authorization: [Monitor), [All]

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• Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

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!Comment I Question 1

!(b)(?)(C) fNRC 10121/2013 12:34:53 PM Summary is based on questions stemming from NRC review of SLDA, dull diligence versus Reviewer guidance Read Aulhorlzation: [Monitor], [All]

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Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC- Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: C:'l

,~ - - - - - - - - - - - ----1(b)(7)(C)

I Comment I Question NRC 10/22/2013 09:25:04 AM Suggest adding Appendix B violation review to Case 13-048 Add Reply Read Authorization: !Monitor), [All]

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Origination Doclink: [j

!Comment/ Question  !(b)(7)(C) I 10/25/2013 08:54:47 AM Cost/Benefit for Fukushima hardened vent. Related to 2014 Strategic Initiatives.

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OFFICIAL USE ONLY Memorandum ofInterview Prepared by:  !(b)(7)(C) ! 09/30/2016 Case

Title:

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Person Being Interviewed:

Date of Interview: 09/29/2016 Location of Interview:

Purpose of Interview:

Allegation Narrative of Interview:

Additional Information:

Request Review:

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OFFICIAL USE ONLY Memorandum ofInterview Prepared by: i(b)(?)(C\ I 09/30/2016 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: .,)

Conducted By: IL_

(b-)(7-)(C

_) _ ___.rNRC,l(b)(?)(C) INRC Person Being Interviewed : .

Date of Interview: 08/25/2016 Location of Interview:

Purpose of Interview:

Allegation Narrative of Interview:

Additional Information :

Request Review:

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OFFICIAL USE ONLY Memorandum ofInterview Prepared by: !<b){7)(C) I 09/30/2016 Case

Title:

'Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: I)

(b)(7)(C)

Conducted By: l*NRc,l(b)(7)(C)

Person Being Interviewed :

Date of Interview: 07/27/2016 Location of Interview:

Purpose of Interview:

Additional lnfonnatlon :

Request Review:

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Title:

Special Project: NRC Case Number* C 13 027 Regulatory Oversight Origination Doclink: D (b)(?)(C) NRC, l(b)(7)(C)

Conducted By: INRC Person Being Interviewed:

Date of Interview: 07/04/2016 Location of Interview:

Purpose of Interview:

l(b)(7)(A)

Narrative of Interview:

Additional lnfonnation :

Request Review:

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OFFICIAL USE ONLY Memorandum ofInterview Prepared by: !(b){7)(C) ! 09/3012016 Case

Title:

Special Project: NRC Case Number; C 13 027 Regulatory Oversight Origination Doclink: J Conducted By: '-r-

)(-7)(_C_) - - ' ~NRC.1(b)(7)(C)

Person Being Interviewed :

Date of Interview: 07/01/2016 Location of Interview:

Purpose of Interview:

Case 16 016 Narrative of Interview:

Additional Information :

Request Review:

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OFFICIAL USE ONLY Case Title : Special Project: NRC 1Case Number: C 13 027 Regulatory Oversight Origination Doclink : [j Conducted By: (b)(?)(C) NRcJ(b)(?)(C) INRC Person Being Interviewed: (b)(7)(A),(b)(7) _ _ _ __.

Date of Interview: 06/15/2016 Location of Interview:

Purpose of Interview:

I(b)(7)(A) I Narrative of Interview:

Additional Information :

SA: Per your comment, redactions have been placed to withhold case material.

Request Review:

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Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: (j 7

7 Conducted By: .,.

<b,.,.

)(,.,,).,., ) _.--___,NRC, ...

(C,.,.. l(b-)(- )-(C_J _ ____,~RC Person Being Interviewed : (b)(7)(C)

Date of Interview: 05/26/2016 Location of Interview: Region I Purpose of Interview:

Case 16 016 Narrative of Interview:

Additional Information:

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Date of Interview: 05/04/2016 Location of Interview:

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Narrative of Interview:

Addltlonal lnfonnation:

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Title:

Special Project NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: ')

Conducted By: l(b)(7)(C) tNRC,l(b)(7)(C)

. _ jNRC,l(b)(7)(C)

Person Being Interviewed :  ;;;l (b"!';

)(7

!;;')(;:;,;

C;= ) --===t.;..;.;,I Date of Interview: 04/07/2016 Location of Interview:

Purpose of Interview:

I(b)(?)(A) I Narrative of Interview:

Additional lnfonnation :

Request Review:

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OFFICIAL USE ONLY Memorandum ofInterview Prepared by: i(b)(7)(C\ I 0411 //2016 Case Title : Special Project: NRC Case Number: C 13 027

'Regulatory Oversight Origination Doclink: [)

Conducted By: ,.,,

(b..,..

)(=?)..,., ) _ _L.:.:..:.i (C,.,.. RC, l(b)(?)(C)

Person Being Interviewed: (b)(7)(C)

L-------....1 Date of Interview: 04/07/2016 Location of Interview: NRC Headquarters Purpose of Interview:

Previous Indian Point Inspector Narrative of Interview:

~

Case 16 016_Mtg~(b)(7)(C) m l ,Aprll 7 2021 .rev 1docx.docx Additional lnfonnation :

l(b)(7)(C) I

..,,..,.,=.------.concurred by Name 04/11/2016 03:14 PM 04/11/2016 03:14 PM Date

..................---.Concurred by Name Date (b)(7)(C) 04/11/2016 03:37 PM 04111/2016 03:14 PM Request Review:

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Conducted By: (b)(?)(C) 1

'NRC NRC Person Being Interviewed: (b)(7)(C)

Date of Interview: 02/ 11 /2016 Location of Interview: Nebraska City, Nebraska Purpose of Interview:

Allegation Narrative of Interview:

~~~x Additional lnfonnatlon:

Date

( b ,..,.,,,

) ( 7 .,..,.,,

)( C,.,....

) --,IConcurred by Name 05/11/2016 01 :23 PM Request Review; OFFICIAL USE ONLY 1

OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 July 11, 2017 (b)(7)(C)

MEMORANDUM TO: Concur: Case Close Joseph A. McMIiian Assistant Inspector General for Investigations (b)(7)(C)

FROM: .

l Office of the Inspector General

SUBJECT:

SPECIAL PROJECT: U.S. NUCLEAR REGULATORY COMMISSION REGULATORY OVERSIGHT (OIG CASE NO.13-027)

Recommendatio~

This project is being closed and a new project with the same objectives has been reopened in fiscal year 2017, Office of the Inspector General (OIG) Case No.17-007 pertains.

Project Conclusion This project was initiated in April 2013 as a mechanism to identify potential investigative matters associated with U.S. Nuclear Regulatory Commission (NRC) technical and regulatory oversight where individual misconduct was not identified as a concern. Over the course of this project, a total of 33 allegations were correlated to it. These allegations were monitored for potential developments and dispositioned accordingly.

Examples of allegations that were either dispositioned as Preliminary Investigations, Referrals to NRC or OIG/Audits, or Closed to the Files of this office were:

°'IS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGULATORY COMMISSION, OFFICE OF THE INSPECTOR GENERAL. (OIG). IF LOANED TO ANOTHER AGENCY, ll AND ITS CONTENlf'S ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE ftfE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY-OIG INVESTIGATION

OFFICIAL USE ONLY- o,G INVESTIGATION INFORMATION

• Non-Working Monitor at Xcel Prairie Island Nuclear Station (A13-07193)

• Concerns Regarding NC State Laboratory (A 13-07301)

• Lack of Rigorous Oversight By NRC of Plant Problems at The Fort Calhoun Station (A 13-07185)

Also, a number of technical issues were proactively evaluated and some of them were dispositioned as investigations. Examples include:

• NRC Oversight of St. Lucie Nuclear Power Plant Main Steam Isolation Valves During Component Bases Inspection Process (C 15-013)

• Failure to Identify Potential Problems With a Safety Relief Valve During a Component Design Inspection at Pilgrim Nuclear Power Plant (C 15-029)

This project supported 27 investigations to include:

• NRC RIV Handling of Replacement of Steam Generators at San Onofre Nuclear Generating Station Under the 10 CFR 50.59 Process (C 13-006)

• Concerns Pertaining to NRC Region II Management and Inspectors Failed to Perform Direct Containment Close Out (C 15-041)

A number of the correlated allegations will continue to be supported in the subsequent project to include:

• (b)(?)(A)

• Concerns Regarding Nuclear Fuel Services Process of Uranium Hexa-fluoride (A 14-07535)

. l(b)(?)(A) 2 THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAA REGULATORY C0Mt.11SSION, OFFICE: OF THE INSPECTOR GENERAi.. (OIG). IF LOANED i-o ANOTHER AGENCY, IT ANO ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY - OIG INVESTIGATlON INFORMATION

.._b....... . ..__ _ _ _____, REVIEW 7...,C CASE FILE NUMBER 16 016 NRC Office of the Inspector General PAGE 1 OF 1 PAGES DETAILS Memorandum to File 7

On April 7, 2016, Case Agen~(b)(?)(Cl ~ ndl(b)(7)(C) I i nterviewed._(b-)(_l_

(c_i ---1.,....,..,.,.,.,~

~ at NRC Headquarters in Rockville, Maryland In regards to the lnvesflga~lon 16 016. In particular, (

L___J was named as an inspector on the March 11, 2011, "Indian Point Nuclear Generating Unit 2- NR_ __

Temporary Instruction 2515/183 Inspection Report 05000247/2011009." This inspection report references review of corrective action (CR-IP2-2011-1717) titled, "28 sump pump in the fuel storage building testing issues." The NRC had no findings associated with this corrective action.

graduated i with a bachelor's degree in electrical engineering from University of Maryland and a e in system's engineering in [~,<7' from Cornelia University.

started at the NRC in 2005 in Region I. He became inspector qualified in 2007. From 2007- 2009, (b)(7)(C)

~w ....................... nal inspector for Electrical and Fire Protection, Eng Branch 3. From (b)(7)(C)

_ _ _ _ _ _ _ _ _....l'n 2013l(b)(7)(C) ~ook a position in NRO, Risk a...n....,....,.....................-..--....-~----....

!(b)(7)(C) ~id baseline inspections as part of ROP (about 50% of his time) and was a communicator when an event occurs (about 50% of his time)

Although (b)(?)(C) was named in the March 11, 2011 Inspection Report discussed above, he believes he only "minimal y e pe with this inspection. He believes (b)(7)(C) did this inspection (i.e. he called it 183 which is referenced in the report.) There was ano er s1m1 ar mspec 10n 1.e. e called 185) that he mainly did.

l(b)(7)(C) aid these inspections (i.e. 183 and 185) were mainly data collection and not physical walk-downs of equipment. The inspectors were looking to see if there were any issues with the sumps.

(b)(7)(C) does not remember the 28 fuel storage sump pump and physically doesn't know where the pump is.

doesn't remember this sump pump being inspected in routine inspections .

.___ __.described IP 71111.01-Adverse Weather Protection - as noted on page 9-10 of inspection report. Flood prot ection equipment - looks at IEE on external plants - important rooms. If "risk significant - due to external events

- inspections are being done. When SRI or RI do flood inspection, they usually look through corrective action reports.

(b)( ( ) NAME \ SIGNATURE DATE REVIEWER NAME\ SIGNATURE DATE l(b)(7)(C)

THIS DOCUMENT IS THE PROPERTY OF THE U.S. NUCLEAR REGUI.ATORV COMMISSION, OFFICE OF THE INSPECTOR GENERAL (OIG), IF LOANED TO ANOTHER AGENCY, IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT OIG'S PERMISSION.

OFFICIAL USE ONLY- OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: March 2016

September 6, 2016 Project 13 027 4 th Quarter 2016 Summary (July)

~gu::*::nth of July, the~rovide support to the special agent for the following cases.

The "red" font provides new information added to this summary (since June 30, 2016) and the black font being previous information.

Executive Summary:

Significant analysis for the followmg cases:

r b)(7)(A)

4. Case16 016, Indian Point Tritium Leak r (7)(A)

(1) Case 16 001; NRO Pre-decisional Release of Information: Awaiting review of final CTF memo. CA is re-writing per recent revieww~ Jassisted the CAl(b)(7)(C) 1who is assigned to this case. Although it is not categorized a c echnical case, the underlying investigation is based on technical documents produced by NRO engineers. For this investigation, t h e ~

assisted with the following actions: (1) did ADAM searches for the document properties (3 Mls),

(2) determined the "availability" and "date of release fields"' were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the Mls (i.e.

ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined "who" actually submitted the document in ADAMS (i.e. l(b)(?)(C) I* (5) discussed "why" BCs would leave individual names in the doc1:1ment that was publicly released, (6) research the policy/procedures for the "Open Door Policy" when meeting with .a Commissioner, and (7) coordinated conversations with CA f o r ~ t o ensure communication and alignment between cases.

rb)(7)(A),(b)(7)(C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(7)(A)

(5) Case 13-042, Fort Calhoun Proactive Initiative. Believe this case will not be opened since FC has announced It will be shutting down? Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically, 0/G should attempt to determine why the NRG in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

(6) Case 15-028, Indian Point (May 2015 Ltr to Mr. Bell). SSA jlbl(?J(C) 11s handling this case independently as of the last briefing (April timeframe.) CAl(bl(7l(C) !,and I~Jmet to discuss the status of this case. CA reported that he is addressing 2 specific issues c . . the tank ~ontents and 2.206 process and lack of a formal letter) and has been reading/following all the addition*a1 information BLANCH has summited to OIG since Fall 2015. This includes the "36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

(7) Case 15 013, St. Lucie MSIV CDBI Inspection. ss4(ol( 7l(Cl lis handling this case independently. No new update. T he following was reported in the last quarter summary, "St.

Lucie MSIV failure after Component Design Basis Inspection (COB/). Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation."

(8) Case 15-029, PIigrim SRV CDBI Inspection. SSAI~~?) lis handling this case independently No new update. The following was reported in the last quarter summary, "Pilgrim SRV failure after a GOBI. Provided the Case Agent with 2 MTFs that identify the areas

NRC provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation."

(9) Case 16 013, NRC misuse of Funds. CA is awaiting CTF memo to be approved[ TJ tas supported CA l(b)(7)(C) I ~~

with this investigatione _ rssisted by: (1) contacted NRR ec nical (C) advisor and received confirmation from the staff that both rules that were described in the FRNs have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the information gathered for this case. The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates.

The CA is currently pursuing a copy of the contract.

( 10) Case 16-012, NRC inappropriate process for digital control RIS. CA is awaiting CTF 7

rnerno to be approved e:! CJ has supported SA (b)( )(C) with this investigation. SA has b )

submitted a CT F memo w ich is pending. (CJ ssisted by; (1) participated in the interview of the PM, (2) reviewed material for the 1/22/16 pu Ic meeting, (3) discussed this area during a meeting with Dave Lochbaum which is documented in a MTF, and (4) met withl(b)(7)(C) 6 7101 I

(current OIGJJ,tndl' ' ' I* He explained the snuation wtth ex-branch a lates to this case. In Magnum are several Chron Notes documenting; b )

support activI't'Ies_ (7) c (11) Case 16 016, Indian Point Tritium Leak into Hudson River. is continuing to support CA (b)(7)(C) . . mb .

1th this case. CA and (7) met (July 28th ) to discuss the

. r)(7)(C) script of _ __,,_ _ __

I

[J (C) .

(b)(7)(C) prepared a tee al presentation durmg the week of August 15th to OIG management t cribe the tritium situation and to create MTFs for the technical analysis and poI.icy concernsmb ) .Is awa1*t*Ing for CA to set up .in tervIews

. wI'thl(b)(?)(C)

.__ _ _ _ _ __ I (7) mb)

(12) Case 16 O , ukushima FOIA, No new update. (7) upported CA~ A by setting up and participating in a meeting with the alleger, Dave CH BAUM. Based on the discussion, LOCHBAUM might withdraw his allegation. l[~l) r *epared a MTF with details and analysis from the meeting. c (b)(7)(A),{b)(7)(C)

(b)(7)(A),(b)(7)(C)

(15) Case 16 035, Conflict of lnterest, lm j assisting CA by acquirtng and revie..;ng ADAMS documents for concurrency by subject w1 hin the last 3 years. Also, provided regulation and Management Directive that NRC employees are instructed to follow when seeking outside employment. Also did research on 5 companies and their nexus to NRC.

(16) Security Project, ~~~ completed a MTF for ss+b)(?)(C) I .

regarding 1(6)(7)1

~ reports

. (C) related to security.

(b)(7)(A),(b)(7)(C)

(18) Case 15 041 - .... r _)(?-)(-C)_ _ _ _ _ _lentered containment. ~~~ and (b)(?)(C) met with OGC and requested answers to the following questions: (C)

1. Did the NRCl(b)(7)(C) I. by not declaring )( violate 10 CFR 50.9?

2. Did the NRC l(b)(7)(C) l by not declaring and entering containment, violate 10 CFR 50.70(3)?

3. Did the NRCl(b)(7)(C) t violate 10 CFR 20.1003?

4. Did the NRC } b)f7)<C} f violate 10 CFR 20 .1208?

5. Per NRC regulations/ olic / rocedure/guidance, should have the NRc!(b)(7)(C)

(b)(?)(C) declared (b)(J)(C) iven that she was !(b)(7)(C)  !? """"...,,..,..-,

6. .......--.-....I..... censee keep eir own employee out of containment even if she iJ(b)(?)(C) but doesn't "declare"? If so, how can they not prevent a NRC employee who is (b::;::;C

;

:l<!;Jl; ::::::=--....1..1rom going into containment?

7. s ere a I ucIary duty and/or regulation/policy/procedure/guidance, as ~(b.,i,<? i,)""'

)(C,...)..................,

(Branch Chief, etc.) to protect the health and safety of an employee and

8. Is the Bra~~!,,,W,<,U.U.....l.Ll,"""1,,1.W.U,.MJ..........,................................................... procedure/guida_n_ ce....,1"'"'h . -e- -

a llowed a (b)( < l to enter containment?

9. Did NRC's decision to allow the (b)(7)(C) to enter containment, put the Agency at risk?

10. Did using the Licensee's equipment (video camera) and partial walk-down of containment meet the intent of the Inspection Procedure 711111.20?

(b)(7)(A),(b)(7)(C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)( 4), (b)(7)(A) , (b)(7)(D)

(b)(4)

(b)(4), (b)(7)(D)

(3) Economic Esplonage*I7lJ and CA discussed potential technical interest in new technology.

(CJ Specifically, CA discusse small modular reactors (SMR), (CJ has experience with SM Rs and

. . (b)(7)(C) agreed to set-up a meeting with spoke withl(b)(7)(C) Ion the ph._o_n_e_a_n_d_h_e_a_g_r-ee_d_t_o_m

- ee_t___H_e_m_ e-nt-io_n_e_d_t-ha_t_h_e_h_a_s_w_o.....

rked with NSIR In the past on this subject. Meeting has been set for June 15, 2016.

(b)

Durln this review rlod ~~}) communicated with the followin Stakeholder Grou s:

(1) Dave Lochbaum - On January 20, 2016, Dave Lochbaum was at NRC HQs and met with Ol~nd SAl(b)(?)(C) ~ The following items were discussed:

• ~ e r Study- Industry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (i.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk. All in all, the results did not have any statistical outliers they were deemed significant but the study did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aware of any "international" or "regulatory changes" related to this study as described in Case 16-013.

• The Special Interest Group guru for radiation dose i1(b)(l)(C) I Dave will e-mail his contact information.

• Dave is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRC would require "evaluations" - not simple function testing - in order to demonstrate that

equipment past its service life is still safe. The industry does not want evaluations to be used as a control point.

• Pale Verde - Dave.is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

(2) Paul BLANCH - on March 17, 2016,Wi"land Deputy AIGI Had a phone conversation with Paul Blanch regarding the letter BLANC~te to Mr. Bell in March 2016. He alleged NRC's oversight was not appropriate. l~~r) lnotes from the meeting include:

A. BLANCH's top 3 issues: [1] Violation of MD 8.5 and 8.11 (2.206 Petition}, [2] IP operating in an unanalyzed condition, and [3] from Blanch's letter... item #5. Buried portion has never been analyzed. But does it need to be? OIG to check. NRC said ~

~ L__j LJ (b}(7)(C) told him, "the above ground portion has been analyzed." Pe .___..... n 2008, it wasn't analyzed ...however, there was an allegation in 2008 about the gas line near the river...800 feet away..in response to that allegation .... NRC responded a rupture won't jepordize the safety structures. But.,.they didn't se,em to analyze the buried portion (in 2010 Paul did a petition) told him they just analyzed the above ground portion.

8. Paul said, "We can conclude the NRC has not done an adequate risk assessment....operatlng in an unanalyzed condition. We can't direct the AGENCY but we could send to the EDO and Commission and hopefully they will take action.

(b)

C. Dave Lochbaum -On March 10, 2016, (?) met with LOCHBAUM. At the meeting, (C)

LOCHBAUM shared the following Infer n:

• He met with the FOIA office regarding his concern with Fukushima FOIA requests. A separate MTF has been developed regarding this topic.

• He discussed his current project which is researching, reviewing, and understanding why NRC has a large number of RAls. He believes industry is putting pressure on NRG to reduce RAls. However, LOCHBAUM is looking into10 CFR 50.9 to see if Licensees are really the ones who need to be accountable for providing complete and accurate information.

• He is waiting for NRC to put all UFSARs back in ADAMS per SECY,

~

During this perlodl Jsupported OIG efforts to:

(1 ). Dave Lochbaum Meetlng.1~l lmet with Dave LOCHBAUM prior to the Commission Meeting ,n which Dave LOCHBAUM was a guest speaker LOCHBAUM shared his views of the

NRC safety culture. During LOCHBAUM's meeting with OIG, he described several areas within the 2.206 petition process that Stakeholders are concerned about . (b)(?)(C) arranged for 2 OIG a udit personnel to join the meeting with LOCHBAUM.

(2) Attended the Commission Meeting on July 26, 2016, titled, "Meeting with NRC Stakeholders." During the meeting, the subject of "FLEX equipment" was often discussed.

The information regarding FLEX equipment was shared with SSA~ because it has applicability to hiS!(b)(7)(A)

(b)( 4), (b)(7)(C), (b)(7)(0 )

(b)(7)(A),(b)(7)(C)

(4) Training for Special Agents - Prepared an update and summary to the SA Technical Training Plan and plan to AIGI during the 1st week of August. Currently working on Sept 9th T raining during All Hands meeting.

b (5) Interface with OIG Audits ~2) talked to Paul about 2.206 petition audit for next year. Also talked to 2 audi o s on Paul's team. Provided ideas and background on Stakeholder's concern with 2.206 petition. Shared notes from 2013 meeting with Stakeholders.

(b )(?)(A),(b)(7)(C)

(b)

(3) Allegation 15-07582 - UFSAR Public Availability in ADAMS. ~6)) discussed this allegation with alleger, David LOCHBAUM. ,w, r eeds to develop a memo for this allegat,on. The NRG reversed a SECY base on LOCHBAUM's request. To datef l, lis still working with LOCH BAUM to see if his concern with UFSARs has been resolved. ir example, DC was just added to ADAMS in March 2016k which is approximately 1 year since it was docketed in Still monitoring delays in making FSAR publically available.

(4) Allegation 14 07379 - Chrystal River Seismic Concerns. Still working on Closure Memo. No new update. Has been delayed due to prioritiies. Will try to get to Joe by Nov 10th COB. Region ll's Allegation Review Board's review of seismic concerns with Chrystal River -

The alleger believes the numerous engineering concerns he proved to Region II were not adequately addressed. (b)(l)(C) reviewed the information provided by the alleger and identified a potential gap in the review process by the engineer who was tasked with assisting with this

. (b)(7)(C) .,,.

(b.,..,,

)(7.,..,.

)(C " "')----,

a IIegat,on. _ _ _met with engineer to understand the process the engineer followed.

is still in the process of developed a closure MTF for this allegation. ---

(b)(7)(A),(b)(7)(C)

(b)

(6) Interface with OIG Audits - ~6\ et with ASME audit team twice and introduced the audit manager to a NRC sta eavily involved with ASME code committees.I~~\(?) I and Audit Manager have another meeting set up for Sept 7, 2016.

,.,.,...,...,=,,.,.,,.,..---, (b)(7)

(7)

(b)

(7)

(C) was briefed by l(b)(?)(C)

I. regarding the 50.59 aU1dit OIG is conducting..______,

(C) gested that Audits review all the Special Inspections performed in the last few years and determine if the .equipment that failed was (1 ) previously inspected by NRC a nd/or (2) recently modffied under 50.59. Als1 ~ d ruggested Audi1s review the last 3 years of LERs and _determine the same. Hence, 1 he equipment that failed was (1) previously inspected by NRC and/or (2) recently modified unde r 50.59.Wi'1 also provided information regarding "additional guidance" Industry utilizes.7Teaning, NEI 96 07 is not the only guidance used by Licensees. E)agree to obtain the name of the additional guidance. Overall, it appears this audit is leading to many lose ends that appear to impact the effectiveness of NRC oversight of 50.59. Also, 50.59 audits might be eliminated per Project AIM. (b)

(8) Interface with OIG Audits - Materials Teams (?) met with the Material's team to items related to NRC"s oversight of material e (C) fflfl s~shared past and current

Kitg:;~0::1::::'::: ::!:::1::~~:es::~::t~;~:ea:ud~tam will be reaching out 1

(9) O~ed the presentation material discussed in the April 11, 2016 NEA newsletter regarding, "NEA S~ar on Lessons Learnt from the Waste Isolation Pilot Plant (WIPP)." Currentl~ls planning to discuss with AIGI the next steps.

The seminar summary states:

Recognizing the importance of safety c;ulture and the impact of managerial and human factors on safety performance In the management of radioactiv~ waste, the NEA held a seminar on 31 March 2016 to examine the lessons learnt from the accidents that occurred at the Waste Isolation Pilot Plant (WIPP) in 2014. Located In southeast New Mexico, the WIPP is the only deep geological repository for permanent disposal of transuranic waste in the United States. In February 2014, two isolated events - a fire and a radiological release - took place at the WIPP, triggering a rigorous accident Investigation process. The NEA seminar reviewed the danger of complacency in the workplace and discussed means to create a safety-focused organization. The meeting discussions also revealed the effectiveness of social media as a communication tool. Participants underlined that emergency

communications need to be open and transparent with the public In order to be effective and efficient."

Planned Investigative Activities:

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytics Other Documents:

Innovative Activities (1 )ll2illworl<ing on a global summary of AIGl's use to brief NRC Offices.

lnterv ews:

(b)(7)(A),(b)(7)(C)

Engineering Intern:

Tasks:

1 (b)(?)(A), (b)(7)(C)

2. t 1jt. 101 v _ n1 w ..,l. sm1c. v 11 , ' 011 p ete - ~enr 10 1 l c' r A* n J 11,b 7. 101~. , L t,~L ronh..allv ap , ,ved - dWaitioq sicwed com,,

(b)(7)(A ), (b)(7)(C) j j O \ !. lltTF tor iMr. 1745 and IMC 1245 Appendix A* Completed* Sent iI C on Jun 1.> O ri - awaited TL review.

(b)(?)(A), (b)(?)(C) 6 7.

l(b)(?)(C) I August 1, 2016 Project 13 027 4 th Quarter 2016 Summary (July}

Case Update:

During the month of July, the~provide support to the special agent for the following cases.

The "red" font provides new iAftr'ma1ion added to this summary (since June 30, 2016) and the black font being previous information.

Executive Summary:

Significant analysis by Engineering Intern for the following cases:

1 Case l(b)(?)(A)

2. Case 3 Case

4. Case16 016, Indian Point Tritium Leak

5. r )(?)(A)

(1) Case 16 001; NRO Pre-decisional Release of Information: Awaiting review of final CTF memo. CA Is re-writing per recent rev1ewf ~ !ssisted the cAl(b)(?)(C) Iwho is assigned to this case. Although it is not categorized a c chnical case, the underlying investigation is based on technical documents produced by NRO engineers. For this investigation, thel~~?) I assisted with the following actions: (1) did ADAM searches for the document properties (3 MLs),

(2) determined the "availability" and "date of release fields" were pertinent to the inves1igation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the Mls (i.e.

ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined "wh (b)(?) " ally submitted the document in ADAMS (i.e.l(b)(?)(C)

I)I (5) discussed "why' (C) would leave individual names in the document that was publicly released,

<6) research the po icy/procedures for the "Open Door Policy" when meeting with a Commissioner, and (7) coordinated conversations with CA for !(b)(7)(A Ito ensure communication and alignment between cases.

(b)(?)(A), (b)(?)(C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(7)(A),(b)(7)(C)

(5) Case 1.3-042, Fort Calhoun Proactive Initiative. Believe this case will not be opened since FC has announced it will be shutting down? Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically, 0/G should attempt to d etermine why the NRC in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

(6) Case 15-028, Indian Point (May 2015 Ltr to Mr. Bell). SSA (b)(?) is handling this case Independently as of the last briefing (April timeframe.) CA (b)(?) , and ti met to discuss the status of this case. CA reported that he is addressing 2 specific issues I.e. the tank contents and 2.206 process and lack of a formal letter) and has been reading/following all the additional information BLANCH has summited to OIG since Fall 2015. This includes the "36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

(b)(7)

(7) Case 15 013, St. Lucie MSIV CDBI Inspection. SS (C) s handling this case independently No new update. The following was reported in the last quarter summary, "St.

Lucie MS/V failure after Component Design Basis Inspection (GOBI). Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation."

(8) Case 15-029, Pilgrim SRV CDBI Inspection. ss4~~?) I,s handling this case independently. No new update. The following was reported in the last quarter summary, "Pilgrim SRV failure after a COB/. Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component. Additionally, provided a "check off

sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation. "

supported CAl(bl(?)(C) I with this investigation.

advisor and received confirmation from the staff tlia I~

(9) Case 16 013, NRC misuse of Funds. CA is awaiting CTF memo to be approvedm Jassisted by: ( 1 ) contacted NRR%ij,nical oth rules that were described in the FRNs as have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the information gathered for this case. The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates.

The CA is currently pursuing a copy of the contract.

(10) Case 16-012, NRC inappropriate process for digital control RIS. CA is awaiting CTF memo to be approved~ l has supported SA (b)(7)(C) with this investigation. SA has (b

submitted a CTF mem 1ich is pending. (7) assisted by; (1) participated in the interview of the (C)

PM, (2) reviewed material for the 1/22/16 pu 1c meeting, (3) discussed this area during a

( current (b )(7)(C) nd l(b )(7)(C) I meeting with Dave Lochbaum which is documented in a MTF, and (4) met with l(b)(?)(C)

. He explained the situation with

.I

. . (b)(7) ex-branc as 1t relates to this case. In Magnum are several Chron Notes documenting ,(C) _ _ _,

support activities.

~

(11) Case 16 016, Indian Point Tritium Leak into Hudson River. lLcijis continuing to support CA (b)(?J(C) with this case. CA and ~ et (July 28th ) to discuss the transcript of l(b)(?)(C) I (b)(?)(C) . 112, !agreed to pre~ a technical presentation during the week of August 15th to 0IG management to describe the tritium situation and to create MTFs for the technical analysis and policy concerns. i~l (C) is working on this now On April 6, 2016, CA and~~~ had a planning/update meeting on April 6, 2016 and discussed the (C) following:

A. The allegation from, U .S. Senator Kirsten Gillibrand, requested 0IG to:

While I know that the NRC has not yet completed its investigation into the specific cause of the most recent leak, it has been brought to my attention that the leak most

llkely occurred during preparations for the next refueling outage, while waste stream water was moving to the waste storage tank. More troubling are reports that Entergy personnel were aware of related equipment problems as early as 2014, but failed to adequately repair or replace the equipment...... Additionally, I would like information on whether the NRC's resident Inspectors at Indian Point we aware of the malfunctioning equipment which caused the most recent leak, and whether it was flagged as a potential issue at any point prior to the discovery of the leak, and why the decision was made not to repair it in 2014.

B. CA and ~ reviewed Indian Point (IP) prior inspection reports and learned that one of the 201 fPnspection reports referenced the sump pump being questioned in the allegation. Therefore, In NRC Inspection Report dated March 13, 2011, OIG learned from the report that, (page 10): the NRC noted that sump pumps required for mitigation of internal and external flooding were verified by licensee to be satisfactory. Also it stated, "the inspectors reviewed a sample of flood protection equipment testing and maintenance. Documents reviewed by the inspectors are listed in the Supplemental Information Attachment to this report .In Supplemental Information, A-3, Condition Reports, the NRC referenced: CR-IP2-2011-1717, 28 Sump Pump in Fuel Storage Building (FSB)Testing Issues, 4/10/11.

C. On March 4, 2016, l(b)(?)(C) r -mailed to CA that "the name of the sump pump at IP2, thereby contributing to the tritium leak from the reverse osmosis unit is "FSB Sump Pump 28."

D. The inspectors that performed the March 13 2011 dated ins ection were:j(b)(?)(C) f?i3T1'Ti"7 and (b)(7)(C) ~

(b )(7 )(C) is currently ,__..,,..,.,,...,.,.,,---..,,and l(b)(7)(C) Iis currently a (b)(7)(C) in NRO (b)(?)(Cl E. The,(bl(7)(Cl (b.,.,

)(7.,...)(,1>!,

C.- ) ------......i---. sent to assist with the February 2016 inspection was (b)(?)(C) rom Division of Reactor Safety.

F. Reviewed Fukushima Lessons Learned website for IP and found no noted concerns with sump pumps.

Next Steps:

1. Interview j(b)(7)(C) Ifor background infonnation p) Ito generate questions for CA to ask).

Completed April 7, 2016

. (b )(7)

2. lntenvew (C) the inspector who assisted with site inspection in March 2016. Completed May 5, 2016

3. Request NRC e-mails for l(b)(7)(C) IORB), l(b)(7)(C) I, and l(b)(7)(C)

(inspector).

4. Plant visit to review Corrective Actions.

5. Based on items 1-4 above, Interview: !(b)(7)(C)  ! DRB), l(b)(7)(C) I, and l(b)(7)(C)  !(inspector) (b)

(12) Case 16 014, Fukushima FOIA, No new update. ~2) 7 upported cAl(b)( )(C) l by setting up and participating in a meeting with the alll;!lr Dave LOCHBAUM. Based on the discussion, LOCHBAUM might withdraw his allegation. ~7) prepared a MTF with details and analysis from the meeting. (C)

(b)(7)(A), (b)(7)(C)

(b)

(15) Case 16 035, Conflict of Interest, (7) assisting CA by acquiring and reviewing ADAMS (C) documents for concurrency by subject within the last 3 years. Also, provided regulation and

Management Directive that NRC employees are instructed to follow when seeking outside employment.

(b) l(b)(7)(C) L l<§)ml (16) Security Project, \2) completed a MTF for SSA _ _ _ _ _regarding ~ reports related to security.

(b)

Durina this nariod. the (7) reviewed the followina alleaation assianed to her:

(C)

(b)(7)(A),(b)(7)(C)

(b)(?)(A),(b)(7)( C)

(3) Allegation 15-07582- UFSAR Public Availability In ADAMS. Biscussed this allegation with alleger, David LOCHBAUM. ~ ~*eds to develop a CTF memo for~

(b) allegation. The NRC reversed a SECY base LOCHBAUM's request. To date, f{] is still working with LOCHBAUM to see if his concern with UFSARs has been resolved. For example, DC was just added to ADAMS in March 2016k which is approximately 1 year since it was docketed in Still monitoring delays in making FSAR publically available.

(4) Allegation 14 07379 - Chrystal River Seismic Concerns. Still working on Closure Memo. No new update. Has been delayed due to priorities. Will try to get to Joe by Nov 10th COB. Region ll's Allegation Review Board's review of seismic concerns with Chrystal River -

The alleger believes the numerous engineering concerns he proved to Region II were not adequately addressed. (b)(7)(ci' reviewed the information provided by the alleger and identified a potential gap in the review process by the engineer who was tasked with assisting with this ffl:l"l'rm:"I'- - ,

'.i~l[;li~\'

allegation. met with engineer to understand the process the engineer followed.

is still in the process of developed a closure MTF for this allegation. ------

(b )(7)(A),(b )(7)(C)

(b)(?)(A),(b)(7)( C)

(b)(7)(A),(b)(7)(C)

(b)(4), (b)(7)(A), (b)(7)(C), (b)(7)(D)

(b )(7)(A), (b)(7)(C), (b)(7)(0) m Durinci this revfew oeriod (7) communicated with the followinci Stakeholder Groups:

(C (1) Dave Lochbaum - On anuary 20, 2016, Dave Lochbaum was at NRC HQs and met with OIG~W*nd s 1 (b)(YJ(CJ j The following items were discussed:

• C er Study - Industry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (i.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and

understand why these sites were considered high risk. All in all, the results did not have any statistical outliers they were deemed significant but the study did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aware of any "international" or "regulatory changes related to this study as described in Case 16-013.

• The Speci_al Interest Group guru for radiation dose lsl... - )(-cJ_ _ __.I Dave will e-mail (b-)(?

his contact information.

• Dave is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRC would require "evaluations" - not simple function testing - in order to demonstrate that equipment past its service life is still safe. The industry does not want evaluations to be used as a control point

• Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

(b)(7)

(2) Paul BLANCH - on March 17, 2016(C) nd Deputy AIGI Had a phone conversation with Paul Blanch regarding the letter BLANC wrote to Mr. Bell in March 2016. He alleged NRC's oversight was not appropriate. l~~r) pates from the meeting include:

A. BLANCH's top 3 Issues: [1] Violation of MD 8.5 and 8.11 (2.206 Petition), [2] IP operating in an unanalyzed condition, and [3] from Blanch's letter...item #5. Buried portion has never been analyzed. But does it need to be? OIG to check. NRC said (Art Burritt) told him, "the above ground portion has been analyzed." Per Burritt, in 2008, it wasn't analyzed ... however, there was an allegation in 2008 about the gas line near the river... 800 feet away.. in response to that allegation .... NRC responded a rupture won't jepordize the safety structures. But.. .they didn't seem to analyze the buried portion (in 2010 Paul did a petition) told him they just analyzed the above ground portion.

B. Paul said, "We can conclude the NRC has not done an adequate risk assessment....operating in an unanalyzed condition. We can't direct the AGENCY but we could send to the 'EDO and Commission and hopefully they will take action.

(b)

C. Dave Lochbaum - On March 10, 2016, ~2) met with LOCHBAUM. At the meeting, LOCHBAUM shared the following Info n:

• He met with the FOIA office regarding his concern with Fukushima FOIA requests. A separate MTF has been developed regarding this topic.

• He discussed his current project which is researching, reviewing, and understanding why NRC has a large number of RAls. He believes industry is putting pressure on NRC to reduce RAls. However, LOCHBAUM is looking into 10 CFR 50.9 to see if Licensees are really the ones who need to be accountable for providing complete and accurate information.

• He is waiting for NRC to put all UFSARs back in ADAMS per SECY.

(b)

During this period, (7) supported OIG efforts to:

(C) rrITT

( 1). Dave Lochbaum Meeting. ~ met with Dave LOCHBAUM prior to the Commission Meeting in which Dave LOCH BAUM was a guest speaker. LOCHBAUM shared his views of the NRC safety culture. During LOCHBAUM's meeting with OIG, he described several areas within the 2.206 petition process that Stakeholders are concerned about. ~ arranged for 2 OIG audit personnel to join the meeting with LOCHBAUM.

(2) Attended the Commission Meeting on July 26, 2016, titled, "Meeting with NRC Stakeholders." During the meeting, the subject of "FLEX equipment" was often discussed.

The information regarding FLEX equipment was shared with SSAl~~?l !because it has applicability to his l(b)(?)(A) I (b)(4), (b)(?)(C), (b)(?)(D)

(b)(?)(A),(b)(?)(C)

(4) Training for Special Agents - Prepared an update and summary to the SA Technical Training Plan and plan to AIGI during the 1st week of August.

(5) Interface with OIG Audits - ! ltalked to Paul about 2.206 petition audit for next year. Also talked to 2 audit folks on Paul' s team. Provided Ideas and background on Stakeholder's ~ ern with 2.206 petition. Shared notes from 2013 meeting with Stakeh~ *rsfuwas briefed byl(b)(l)(C) Iregarding the 50.59 audit OIG is conducting. (7) suggested that Audits review all the Special Inspections performed in the last few years and determine if the equipment that failed was ( 1) previously inspected by NRC and/or (2) recently modffied under 50.59. Alsof,,tuggesled Audits review the last 3 years of LERs and determine the same. Hence, di 1 equipment that failed was (1) previously inspected by NRC and/or (2) recently modified under 50.59.im, !also provided information regarding additional guidm"industry utilizes. Meaning, NEI 96 07 is not (b) the only guidance used by Licensees. (7) gree to obtain the name of the additional m

guidance. Overall, it appears this aud I eading to many lose ends that appear to impact the effectiveness of NRC oversight of 50.59. Also, 50.59 audits might be eliminated per Project AIM.

(4) Interface with OIG Audits - Materials Teams - ~2) met with the Material's team to (b)(7)

Items related to NRC's oversight of material e s. (CJ hared past and current lnve lgatlon/allegatlons regarding this subject. The I team will be reaching out (b) to (7) nee the team has determined the scope of the audit.

(5) 06 ained the presentation material discussed In the April 11, 2016 NEA newsletter regarding, "NEA Seminar on Lessons Learnt from the Waste Isolation PIiot Plant (WIPP)." Currently !~! is planning to discuss with AIGI the next steps.

(C)

The seminar summa tes:

Recognizing the Importance of safety culture and the impact of managerial and human factors on safety performance in the management of radioactive waste, the NEA held a seminar on 31 March 2016 to examine the lessons learnt from the accidents that occu"ed at the Waste Isolation Pilot Plant (WIPP) in 2014. Located in southeast New Mexico, the WIPP is the only deep geological repository for permanent disposal of transuranic waste In the United States. In February 2014, two isolated events - a fire and a radiological release - took place at the WIPP, triggering a rigorous accident investigation process. The NEA seminar reviewed the danger of

complacency in the workplace and discussed means to create a safety-focused organization. The meeting discussions also revealed the effectiveness of social media as a communication tool. Participants underlined that emergency communications need to be open and transparent with the public in order to be effective and efficien*t . .,

Planned Investigative Activities:

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytics Other Documents:

Innovative Activities (b)

(1) (7) working on a global summary of AIGl's use to brief NRC Offices.

(C)

Interviews:

A. (b)(7)(A),(b)(7)(C) 8.

C.

Engineering Intern:

Tasks:

• r )(?)(A) I

2. Case 16 032 - MTF for USC Article, "Se1sm1c Shift," - Completed - Sent to TL r a(,,, '.ln June 7, 2016, TL electronically approved - awaiting si~ned copy?

(b)(?)(A) as~ lt. O;sl - M f or IMC 124!:I and IMC 1L 5 Appendix A - completed* Sent to TL and CAs on June 13, 2016 - awaited TL review.

(b)(7)iA)

Case 16 016 Technical Briefing August17,2016

Allegation OIG initiated case based on the following e-mail:

• From: McMillan, Joseph Sent: Frida Februar 19

) )

To :,., ,.,.,., . ,_ _ _ _ _ _ _ _ _____,IJ.,;;.;;.._:_.:..:....:::.;:.oov>

Cc: nrc.gov>; r b)( l)(C) I (b )(?)(C)

Subject:

FW: COMMISSION E-READER -- Friday, February 19, 2016 (b)( ?)(C) 1- Let's discuss. I would like to know the extent of NRC personnel knowledge of this incident, how and when it was initially addressed.

(b)(?)(C) 1 Please assign to have someone initiate a Preliminary.

Senator Kirsten Gillibrand Ltr As the NRC continues to inve~tigate the cause of the leak, I urge you to also conduct a top-to-bottom review of the policies and procedures in place at Indian Point to:

1. Maintain its aging infrastructure;

2. Whether additional oversight is necessary to ensure that the highest safety standards are being adhered to; and whether equipment used for radioactive waste handling should also be considered safety related for regulatory oversight purposes.

3. Whether thd(o)(?)cci ~t Indian Point were aware of the malfunctioning equipment which caused the most recent leak

4. Whether it was flagged as a potential issue at any point prior to the discovery of the leak

5. Why the decision was made not to repair it in 2014

10 CFR 2.206 Petition May 10, 2016 Petition Review Board Meeting with Petitioner, M rJ(b)(?)(C)

Turkey Point Nuclear Generating Unit No!-r,--3,..,a'"'n,..,a,...4 ----

OEDO-16-0160-1 PURPOSE For the petitioner, Mr. !(b)(7)(C) I to address the Petition Review Board (PRB) for the petition on Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point).

AGENDA A. Welcome and Introductions Fb}(?)(C}

B. PRB Chairperson's lntroduc*""bu- ,-, .... tr""'K...o....,..

c"" 11""'

a""

11 .

C. Petitioner's Presentation D. Q&A (NRC & FPL)

E. PRB Chairperson's Closing Remarks This meeting is scheduled to last from 2 o'clock PM to about 3:30 PM Eastern Time to allow the petitioner one hour to address the PRB. This meeting is being recorded by the NRC Operations Center and will be transcribed by a court reporter. The transcript will become a supplement to the petition and will be made publicly available.

At this time, the people present at this meeting at NRC headquarters will introduce themselves.

As we go around the room, please be sure to clearly state your name, your position, and the NRC office that you work in, for the record. I'll begin.

- m last name is s elled b 7 C and I am the NRC's

...R

..,,P ,.,.B

_ C_h__

air._

.... M

__ na_m

_e_ is.....(_b_)(7_)_(C_) _ _....... the!(b)(7)(C) for this petition.

(b)( )(C)

Rema inin PRB members at HQ] l(b)(7)(C)

(b)(7)(C) ------------------

{Petition Manager] We have completed introductions at NRC headquarters. Are there any other participants from NRC Headquarters on the phone?

Are there any participants from the NRC Reqion 2 Office on the phone?

[ Regional participants introduce themselves]l(b)(7)(C) ,.__ ___________ ___,

10 CFR 2.206 Petition May 10, 2016

[Petition Manager] Is there an one from Florida Power & LI Turkey Point, on the phone? (b ( l( l

[Petition Manager] Mr. (b)(?)(C) would you please introduce yourself for the record?

[Petition Manager] Thank you Mr. l(b)(?)(C) I. It is not required for members of the public to introduce themselves for this call. However, if there are any members of the public on the phone that wish to do so at this time. please state your name for the record.

[Petition Manager] It is important that we each speak clearly and loud enough to make sure that the court reporter can accurately transcribe this meeting. When you speak, please first state your name for the record .

For those dialing into the meeting, please remember to mute your phones to minimize any background noise or distractions. If you do not have a mute button on your phone. this can be done by pressing the star 6 keys. To unmute, press the star 6 keys again.

At this time, I'll turn the meeting over to the PRB Chairperson, r_ _)(J- )(_c _) _ __

B. Openin g Remarks from PRB Chairperson

[PRB Chair] Welcome everyone, and thank you, Mr. l(b)(?)(C) I for bringing your concerns to the NRC.

The NRC's regulations in Title 10 of the Code of Federal Regulations, Section 2.206, provide a way for someone to ask the NRC, in a public process, to take enforcement action related to NRC licensees or licensed activities. This request is called a 2.206 petition. Depending on NRC's review of the petition, the NRC could modify, suspend, or revoke a license issued by the NRC, or take any other appropriate enforcement action to resolve an issuec The NRC's guidance for processing a 2.206 petition is in Management Directive 8.11 , which is available through NRC's web site.

When the NRC receives a 2.206 petition, it forms a Petition Review Board, or PRB. The PRB consists of a Chairperson, who is an NRC senior executive service level manager. The PRB also has a petition manager and a coordinator. Other members of the PRB are chosen based on the subject of the petition.

Before the PRB meets about whether to accept a petition for further review under the 2.206 process, the PRB gives the petitioner an opportunity to meet with the PRB. That is the purpose of today's meeting. The petitioner has this opportunity to provide additional explanation of or support for his 2.206 petition. The PRB will then consider this information when deciding whether to accept the petition for further review under the 2.206 process.

Today's meeting is not a hearing, nor is it an opportunity for the petitioner, or the public, to question the PRB on the merits of the issues presented in the petition-. No dec ions regarding the merits of this petition will be made at today's meeting. After Mr. l(b)(?)(C) 6 resentation, the NRC and licensee may ask the petitioner clarifying questions in order to better understand the petitioner's presentation.

10 CFR 2.206 Petition .3. May 10, 2016 After today's meeting, the PRB will review the petition and the information presented today to determine whether the petition will be accepted for further evaluation. The PRB's initial decision on whether the,~ ~ ~tition will be accepted for further review will be discussed with the petitioner. Mr. (b)(?)(C) will then be provided another opportunity to address the PRB before it makes its final ecIsIon on whether to accept the petition for further review.

At this point, I will provide a summary of Mr.l(b)(?)(C) !petition and NRC activities to date.

I On March 23rd, 2016, Mr.l(b)(?)(C) submitted a 2.206 petition to the NRC about the discharge of radioactive isoto es and other contaminants into the environment surrounding the Turkey Point site. Mr. (b)(?)(C) requested that the NRC take escalated enforcement action against the licensee and issue a confirmatory order requiring the licensee to take the nuclear reactors to a cold shutdown mode of operation until certain conditions were met. These conditions include the completion of an independent assessment of and corrective actions for the source and impacts of the discharge of radioactive isotopes and other contaminants, and an update to the plants' final safety analysis report.

As a basis for his request, Mr. (b)(?)(C) included two reports in his petition dated March 23rd, 2016. The first report is an attac men to a memorandum dated March 7th, 2016, from the Miami-Dade County Mayor Carlos A. Gimenez to the Miami-Dade County Board of County Commissioners. This report appears to have been prepared by the Division of Environmental Resources Management in the Miami-Dade County Department of Regulatory and Economic Resources. The second report is a study completed by Dr_[(b)(?)(C) ~of the University of Miami. This study is available from the Miami-Dade County epartm e t of Regulatory and Economic Resources web site. On May 8th and 9th, 2016, the petitioner provided twelve more attachments to his petition, which included newspaper articles, NRC and licensee environmental reviews, and the licensee's license renewal application.

On March 29th, 2016, the NRC's petition manager contacted Mr. (b)(?)(C) to discuss the 10 CFR 2.206 process and to offer him an opportunity to address t e PRB. Mr. (b)(?)(C) requested to address the PRB by teleconference prior to the PRB's initial recommen a I0n to accept or reject the petition for review.

On April 7th, 2016, the PRB met internally to determine whether immediate NRC actions were needed based on the issues presented in the petition. On April 22nd, 2016, the NRC's petition manager called MrJ(b)(?)(C) l and left him a message that the PRB determined that his petition did not raise public health or safety issues that necessitated immediate enforcement actions to shut down Turkey Point On April 25th, 2016, the NRC's petition manager contacted Mr.l(b)(?)(C) !about a scheduling change to the teleconference. The petition manager also informed the petitioner that on April 29th , NRG staff would be in Homestead participating in a Florida State Senate workshop about Turkey Point's cooling canal system and provided the petitioner a web site link that had information about the workshop.

This concludes the summary of the activities to date regarding this petition.

As a reminder for the phone participants, please state your name if you speak. This will help with developing the meeting transcript that will be made publicly available.

10 CFR 2.206 Petition - 4. May 10, 2016 Mr!(b)(; )(C) I. I will now turn it over to you to provide any information you believe the PRB should consider when reviewing your petition. You have one hour for your presentation.

10 CFR 2.206 Petition May 10, 2016 C. Petitioner's Presentation

[Petitioner]

D. Questions for the Petitioner

[PRB Chair] At this time, does the staff here at headquarters or at the Region have any questions for Mr.!(b)(?)(C) p.

[PRB Members]

[PRB Chair] Does the licensee have any questions?

[Licensee]

[PRB Chair] Members of the public may provide comments about the petition and ask questions about the 2.206 petition process. However, as I previously stated, the purpose of this meeting is not to question the NRC about the merits of the petition. Are there any members of the public that have any questions?

E. PRB Chairperson's Closing Remarks

[ PRB Chair] Mr. (bl(7JCCJ , thank you for raising your concerns to the NRC and taking the time to speak with us a o r petition. Before we conclude the meeting, does the court reporter need any information for the meeting transcript?

With that, this meeting is concluded, and we are terminating the phone connection.

I MIJ(b)(?)(C) comments:

NRC needs to do an independent assessment and correct the discharge of radioactive isotopes into the environment.

NRC needs to do an independent assessment source of the radioactive isotopes and other containments into the surrounding environment.

l(b)(?)(C) ~ discussed select aspects from the 14 attachments he submitted.

Todayl(b)(?)(C) Iwill discuss attachments 1, 4, 7, 9, 11, 12, 13 and 14.

Brought up Flint Michigan including criminal charges. Didn't protect health and safety of public.

NRC is complacent with regulating Turkey Point. He said, NRC is in bed with the Licensee."

Attachment 4: Elevated levels of tritium ... .4 miles away... which is used for drinking water.

Where is leak coming from? FPL uprates came at a cost. More tritium .. plus ..temperatures have not been able to keep them low. Now, FPL wants to add 2 new reactors. Drinking water wells to the west. Where are the regulators?

Attachment 7: Good timeline of event. Did research in 2010 and needed help from local water.

10 CFR 2.206 Petition May 10, 2016 5,900 acres of a "radiator" type of cooling canals.

Need to stop the salt water from moving I migrating. "Salt water intrusion" Increased power by 15%, only increased by 2.5 degrees cooling water because fossil plant was shut down.

The cheapest method was to add fresh water.. ..started monitoring wells for tritium.

Attachment 9: Salt water plume is not in dispute ... the underground plume is the concern because it goes to Key Biscayne water source.

NRC approved LAR for technical spec temp change to 104 degrees ....the highest in the U.S.

nuclear fleet.

The root cause for needing a temperature increase is the "power uprate."

Attachment 11 and 14: Document section 2.4-15 and 2.4-16 (cooling water canal). Section 3.6.2 ... 3.6-42 .... 3.6-44. Aging mechanism. NRC gave 20 year license extension - without aging management program for the canals.

NRC failed to protect - where is NRC's independent assessment of cooling canal. NRC accepted FPL's assessment. NRC is in bed with FPL.

Attachment 12: LAR for extended power uprate. Environment lmpact.. ..the generation of low level waste will not increase and minimal release of radioactive but will be bounded by the EA statement. Petitioner listed many pages numbers that appear to have statements that are not being met now. Where are the independent assessments??

Attachment 13: ML112280501,r ;)(~ J Biological Assessment, page 5, FPL increase predicted at 2 degree. Where 1 R s 1naepen ent study? Not consistent with NRC mission statement.

FR 44465-44466: look at information related to UHS, ultimate heat sink. Where is NRC's independent study. FPL made assumptions, etc. and NRC bought into it.

Attachment 2: OIG should look at this. FPL used "false" assertions and NRC bought into it.

Bottom Line - NRC is not doing independent assessments and relying on Licensee supplied conclusions. He claims the NRC is an independent agency - where is the independence? NRC granted a Emergent Tech Spec increase to 104 degrees without verifying inputs in Power Uprates.

Questions/Comments l(b)(?)(C)  !- In regards to UFSAR, address cooling water system would funcUon as an ultimate heat sink ... it could handle the heat in the case of an accident. The Licensee doesn't seem to be in compliance with this because it' s NOT a closed water system... because it's leaking into drinking water, etc. This is outside the bounds of the license. If in compliance, how they are In compliance with the function of the UHS.

10 CFR 2.206 Petition May 10, 2016 Public - no questions/comments.

OFFICIAL USE ONLY ChronNote Prepared by.1(b)(?)(C) l 05/08120/6 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: ~

Date: 05/08/2016 (b )(?)(A),(b}(?)(C) l(b)(?)(E) Read Authorization: [Monitor], [All]

j AUow Other Editors: Edit Authorization:

[Management), "'!(b.,...

)(7""'

)(C

) -,

1~w?)rRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by~(b )(7)(C) I 05/08/1016 CaseTIUe: Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: 1 AIGI Primary Proactive Initiative Classification:

Origination DocLink: CJ Date: 05/08/2016 Note

Title:

l@lsummary

~ ~I Note: ~ Woekly s , mma,y_May 8 2016.docx reer-,-)(=?)""""

(E,,.,..)-----,1 Read Authorization: [Monitor], [All]

Allow Other Editors:

Edit Authoriza~"D *

[ManagemenQJb)(7)(C) !

(b)(7)(C) NRC OFFICIAL USE ONLY

l(b)(?)(C) May 8, 2016 Project 13 027 2 nd Quarter 2016Summary Case Update:

( 1) Case.16 001; NRD Pre-d eelsIon al Release oflnformation:l assisted the CA l(b)(?)(C) j who is assigned to this case. Although it is not categorized as a technical case, the underlying investigation is based on technical documents produced by NRO engineers. For this investigation, theft, !assisted with the following actions: (1) did ADAM searches for the document prope Ies (3 MLs), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the history" of two of the MLs (i.e. ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined "who" actually submitted the document in ADAMS (i.e.l(b)(?)(C)

(b)(7)

L (5) discussed "why" (Cl ou ld leave individual names in the document that was* publicly released, and (6) research the policy/procedures for the "Open Door Policy" when meeting with a Commissioner.

(b )(7)(A),(b)(?)(C)

(b)(?)(A),(b)(7)( C)

(b )(7)(A),(b )(7)(C)

(5) Case 13-042, Fort Calhoun Proactive Initiative. Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically, OIG should attempt to determine why the NRG in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

~

(6) Case 15-028, Indian Point. OIG management team, On April 8, 2016R9_Jhad a phone conversation with P. BLANCH to review the 7 questions BLANCH asked in the February 2016 letter to Mr. BELL.l~~\tclinvited SA!(b)(?)(C) l A separate case is in the process of being initiated. To date, the CA has not been named.

CA~ and~ met to discuss the status of this case. CA reported that he is addressing 2 specific issues (i.e. the tank contents and 2.206 process and lack of a formal letter) and has been reading/following all the additional information BLANCH has summited to OIG since Fall 2015. This includes the "36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

ro Additionally, P Blanch calle1d.Jsee Chron note) and reported that he was planning on sending Mr. BELL a letter d (i.e. letter was submitted in March 20r ?J ( equesting an invest~ation into NRC's inadequate oversight at Indian Point. Thereafter, (C) and Deputy AIGI had a phone conversation with BLANCH (see below for specifics of ttie call.) l~l (C) is waiting for this separate case to be opened and plans to support the named CA.

(7) Case 15 013, St. Lucie MSIV CDBI Inspection. No new update. The following was reported in the last quarter summary, St. Lucie MSIV failure after Component Design Basis Inspection (COB/). Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation. "

(8) Case 15-029, PIigrim SRV CDBI Inspection. No new update. The following was reported In the last quarter summary, "Pilgrim SRV failure after a CDBI. Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation."

(b)

(9) Case 16 013, NRC misuse of Funds. ~~)) has supported CAl(b)(?)(C) Iwith this investigation. lfg !assisted by: (1} contacte R technical advisor and received confirmation from the staff that both rules that were described in the FRNs have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the information gathered for this case. The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates. The CA is currently pursuing a copy of the contract.

10 Case 16-012, NRC inappropriate process for digital control RIS.

(b)(?)(C) with this investigation. SA has submitted a CTF memo which Is pending.

ID** supported SA H~f)I assisted by; (1} participated in the interview of the PM, (2} reviewed material for the 1/22/16 public meeting, (3} discussed this area during a meeting with Dave Lochbaum which is documented in a MTF, and (4} met wit~(b)(l)(C) l (current~ and r )(?)(C) l(b)(?)(C) I H I

• d th "t *.

. e exp a1ne "th b h 't I t - -th___ _ _l_ __

e s1 ua I0n :'1 ex- ranc as I re a es to 1s case. n Magnum are several Chron Notes documentin ~\ upport activities.

(11) Case 16 016, Indian Point Tritium Leak I (C) udson River. I!~~) lis supporting CA (b)(?)(C) with this case.

On May 5, 2016, CA an leak ~ ill develop a i nterviewed th~(b)(?)(C) Itasked with inspecting the tritium ased on information described during the interview. Also, the processing of developing a working plan for this case based on SONGS lesson's learned.

(b) i2l is in (b)

On April 6, 2016, CA and i2l had a planning/update meeting on April 6, 2016 and discussed the following:

A The allegation from, U.S. Senator Kirsten Gillibrand, requested OIG to:

While I know that the NRC has not yet completed its investigation into the specific cause of the most recent leak, it has been brought to my attention that the leak most likely occurred during preparations for the next refueling outage, while waste stream water was moving to the waste storage tank. More troubling are reports that Entergy personnel were aware of relatea equipment problems as early as 2014, but failed to adequately repair or replace the equipment... ... Additionally, I would like information on whether the NRC's resident inspectors at Indian Point we aware of the malfunctioning equipment which caused the most recent leak , and whether it was flagged as a potential issue at any point prior to the discovery of the leak, and why the decision was made not to repair It In 2014.

B. CA and m eviewed Indian Point (IP) prior inspection reports and learned that one of the 201 (C pection reports referenced the sump pump being questioned in the allegation. Therefore, In NRC Inspection Report dated March 13, 2011 , OIG learned from the report that, (page 10): the NRC noted that "sump pumps required for mitigation

of internal and external flooding were verified by licensee to be satisfactory. Also it stated, "the inspectors reviewed a sample of flood protection equipment testing and maintenance. Documents reviewed by the inspectors are listed in the Supplemental Information Attachment to this report .In Supplemental Information, A-3, Condition Reports, the NRC referenced : CR-IP2-2011-1717, 28 Sump Pump in Fuel Storage Building (FSB)Testing Issues, 4/10/11 .

C. On March 4, 2016, l(b)(?)(C) l e-mailed to CA that "the name of the sump pump at IP2, thereby contributing to the tritium leak from the reverse osmosis unit is "FSB Sump Pump 28."

D. The inspectors that performed the March 13, 2011 dated inspection were: (b)(?)(C) and (b)(7)(C) .~ is current1yl(b)(?)(C) land (b)(?)(C) is currently < < < in NRq <6l<7KC) I-E. The!<b)(?)(C) !sent to assist with the February 2016 inspection was l(b)(?)(C) l(b)(?)(C) !from Division of Reactor Safety.

F. Reviewed Fukushima Lessons Learned website for IP and found no noted concerns with sump pumps.

Next Steps:

1. lnterview '""l(b...,..)(=7)(C

,....,..,,..,.)--,I- for background information F,'" ~o generate questions for CA to ask)

2. lnterivewj(b)(?)(C)I- the inspector who assisted with s1 e inspection in March 2016

3. Request NRC e-mails tor!(b)(?)(C) l oRB), l(b)(?)(C) 1* and r:-:l(b~)(=1)=(c:-:--

) --,I (inspector).

4. Plant visit to review Corrective Actions.5. Based on items 1-4 above, Interview: l(b)(7)(C) l~~~(c l DRB), l(b)(?)(C) I,andl(b)(?)(C) t inspector)

(b)

On April 7, 2016, CA an (7) interviewed l(b)(?)(C)

(C)

I A MTF of the interview is in the case file.

ITT r uadded Inspection Procedure (IP) 71111 .01 "Adverse Weather Protection" and the March

~o11 Inspection Report to the case file.Im I identified that "corrective action records" are required for review per IP 71111 .01 . (C

( 12) Case 16 014, Fukushima FOIA, m upported CA (C) participating in a meeting with the alleger, Dave LOCHBAU M. Based on the discussion, (b)(7) -

A by setting up and

(b)

(7)

LOCHBAUM might withdraw his allegation. (C) repared a MTF with details and analysis from the meeting.

(13) Case 16 033, NRC Management Pressure to Administer Reactor Operator Examinations Pertaining to New Reactor Sites~~ t upported c~)~i"' Iby reviewing the material provided in the allegation. Additionallyjfcf, Ipc 10 pated in an interview with the allegerJ<bJ(?)(C) I 7

~~)( ) provided a historica account of the events/decisions that NRC has made. He believes that Region II management pressured the Region II l(b)(7)(C) Ito administer the reactor operator examination even though OGC informed Region II they shouldn't because they would be in violation of the Atomic Energy Act. The Atomic Energy Act has statements regarding continuity for testing within 30 days. Continuity includes the written exam, simulator testing, and job/plant tests.

{bf (7)

Durina this oeriod the (C) reviewed the followina alleaation assianed to her:

(b )(7)(A),(b)(7)(C)

(b)(?)(A),(b)(7)( C) r (7)(A),(b)(7)(C)

(3) Allegation 15-07582 - UFSAR Public Availability in ADAMSJ~ !discussed this allegation with alleger, David LOCHBAUM. The NRC reversed a S based on LOCHBAUM's request To date,~is still working with LOCHBAUM to see if his concern with UFSARs has been resolved. For~mple, DC was just added to ADAMS in March 2016k which is approximately 1 year since it was docketed in Still moniitoring delays in making FSAR publically available.

(4) Allegation 14 07379 - Chrystal River Seismic Concerns. Still working on Closure Memo. No new update. Has been delayed due to priorities. Will try to get to Joe by Nov 101h COB. Region ll's Allegation Review Board's review of seismic concerns with Chrystal River -

The alleger believes the numerous engineering concerns he proved to Region 11 were not adequately addressed. ~ reviewed the Information provided by the alleger and Identified a potential gap in the review process by the engineer who was tasked with assisting with this

. (b)(?)(C) . * * "'l(b..,..,

)(""'

7)("C,-

") ---,

allegation. _ _ _met with engineer to understand the process the engineer followed . .__ ____.

is still In the process of developed a closure MTF for this allegation.

(b)(?)(A),(b)(7)(C)

(b )(7)(A),(b)(7)(C)

(7) Allegation 16 07859 - ~ reviewed the information in Magnum. 1m~ elieves the N RC has allowed Licensees to modify the plant with license conditions that are knowingly inadequate to meet NRC guidance. CA has not approached Wf War support.

(('\

(b)(7)(A),(b)(7)(C)

Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 Region IV counterpart meeting. See Chron note for further details. appears NRC reviewed in ROP inspection this component that ultim~

failed. MTF will be drafted if research indicates NRC had ,a potential lapse in oversight. d will follow-up on this allegation next quarter. (C)

(b)( 4), (b)(?)(A), (b)(?)(C), (b)(7)(0)

(b)(7)(A),(b)(7)(C)

Other event/concerns related tol(b)(?)(A) I: (as described In last Quarterly Summary)

(b)(4), (b)(?)(C), (b)(?)(D)

(b)(4), (b)(?)(C), (b)(7)(0)

(D)

Durina this review oeriod. (7) (C communicated with the followlna Stakeholder Grouos:

(1) Dave Lochbaum - On January 20, 2016, Dave Lochbaum was at NRC HQs and met with OIG ~and SAl(b)(7)(C) IThe folk>wing items were discussed:

• C er Study - Industry has decided not to pursue a 2.206 for can cellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they

Will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (i.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk. All in all, the results did not have any statistical outliers they were deemed significant but the study did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aware of any "international" or "regulatory changes" related to this study as described in Case 16-013.

• The Special Interest Group guru for radiation dose is... 116_)(-? )(-C)_ _ __,I Dave will e-mail his contact information.

• Dave is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRC would require "evaluations" - not simple function testing - in order to demonstrate that equipment past its service life is still safe. The industry does not want evaluations to be used as a control point.

• Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

(2) Paul BLANCH - on March 17, 2016, , land Deputy AIGI Had a phone conversation with Paul Blanch regarding the letter BLANC wrote to Mr. Bell in March 2016*. He alleged NRC's oversight was not appropriate. li~~(Cr otes from the meeting include:

A. BLANCH's top 3 issues: [1] Violation of MD 8.5 and 8.11 (2.206 Petition), [2) IP operating in an unanalyzed condition, and [3] from Blanch's letter.. .item #5. Buried portion has never been analyzed. But does It need to be? OIG to check. NRC said (b)(?)(C) 1{6)(7)(C) , told him, "the above ground portion has been analyzed." Pe~ in 2008, it wasn't analyzed ... however, there was an allegation in 2008 about the gas line near the river...800 feet away .. in response to that allegation .... NRC responded a rupture won't jepordize the safety structures. But...they didn't seem to analyze the buried portion (in 2010 Paul did a petition) told him they just analyzed the above ground portion.

B. Paul said, 'We can conclude the NRC has not done an adequate risk assessment....operating in an unanalyzed condition. We can't direct the AGENCY but we could send to the EDO and Commission and hopefully they will take action.

C. Dave Lochbaum - On March 10, 2016,m met with LOCHBAUM. At the meeting, LOCHBAUM shared the following lnform~ n:

• He met with the FOIA office regarding his concern with Fukushima FOIA requests. A separate MTF has been developed regarding this topic.

• He discussed his current project which is researching, reviewing, and understanding why NRC has a large number of RAls. He believes industry is putting pressure on NRC to reduce RAls. However, LOCHBAUM is looking into10 CFR 50.9 to see if Licensees are really the ones who need to be accountable for providing complete and accurate information.

• He is waiting for NRC to put all UFSARs back in ADAMS per SECY.

During this period, (~! supported OIG efforts to:

(C)

(1). DOE OIG. ...._ __

(b)(?)(C) ___. prepared a presentation for DOE AIGI , MrJ(b)(?)(C) L The presentation focused on NRC's mission with DOE/NRC common connections" identified throughout the presentation. The link to the presentation is listed below.

(b)( 4), (b)(7)(C), (b)(7)(0)

(b)(7)(A), (b)(7)(C)

(b)

(3) Training for Special Agents (7) presented the DOE/NRC power pornt to ~ per Tl's (C) ~

request on Apnl 11 , 2016 Part 2 of Reactor Concepts Training was completed on February 4, 2016. All the training material is included in a chron note within 13 027.

Prepared an update to the SA Technical Training Plan and presented during February OIG Strategic Planning Meeting.

Second and third quarter training includes S-201, Materials Controls, Security Systems and Principles course (taught by TTC Staff) and ADAMS training (in ilearn). ~~~ is working with Team Leaders to get folks registered and completion of these courses. (C) ll (3) Interface with 0IG Audits * !L.2.r as briefed by 1(b)(?)(C) Iregarding the 50.59 audit OIG is conducting. 1 m, !suggested that Audits review all the Special Inspections performed in the last few years anti determine if the equipment that failed was (1) previously inspected by NRC and/or (2) recently modified under 50.59. Also,m !suggested Audits review the last 3 years of LERs and determine the same. Hence, did the equipment that failed was (1) previously inspected by NRG and/or (2) recently modified under 50.59.[ Jalso provided information regarding "additional uidance" industry utilizes. Meaning, NEI 96 07 is not the (b) only guidance used by Licensees. (7) agree to obtain the name of the additional guidance.

(C)

Overall, it appears this audit is lea ing to many lose ends that appear to impact the effectiveness of NRG oversight of 50.59. Also, 50.59 audits might be eliminated per Project AIM. (b)

(4) Interface with 0IG Audits - Materials Teams - (?) et with the Material's team to (C) items related to NRC's oversight of material exports. ~b) (7) shared past and current investigation/allegations regarding this subject. The au 1t team will be reaching out to ~~~ once the team has determined the scope of the audit.

(C)

Planned Investigative Activities:

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytics Other Documents:

DOE Presentation:

7 C:\Users\TXS7\Documents\XPMigratedFolder~__ (b_)(_ )_(c_)_ __.~NRC_DOE_March 15 2016.pptx Innovative Activities (b)

( 1) (7) working on a global summary of AIGl's use to brief NRC Offices.

(C)

Interviews:

l(Case 15 034)

l(b)(?)(C)

April 13, 2016 50.59 Recommendations for OIG Audits From SONGS (Case 13 006)

Issue 1. Missed Opportunities During NRC Region IV 2009 Inspection,

• How many other 50.59 inspections "miss" the finding which ultimately result in failures of components A. 50.59 Findings impact on ROP columns?

8 . Impact on Events

a. Review LERs

b. Review Special Inspections

c. Compare to NRC Inspection Reports

i. St. Lucie Main Steam Isolation Valve ii. Pilgrim Safety Relief Valve iii. Others Issue 2. AIT Review of SC E's 10 CFR 50.59 Evaluations.

• Licensees use "other" guidance

d. For example, USA Resource Manual Issue 3. NRC Oversight of SONGS UFSAR.

• Appears PM's are doing a "paper/sample check." Does that agree with 10 CFR 50.71(e)

(b)(?)(A),(b)(7)( C)

(b)(?)(A), (b)(?)(C)

(b )(7)(A) l(b)(?)(C) March 30, 2016 Project 13 027 2 nd Quarter 2016Summary Case Update:

(b)

=.:...:.:..:........:;:...:..:..::.....c.=..:..,ri=o=d"-'t:.:.:h;.;:;.ie(7) ort to the s

• ent for the followin cases:

(C)

(1) Case 16 001 ; NRO Pre-decisional Release of lnformation:rwflassisted the CA I )(?)(C) Iwho is assigned to this case.

(b lMJ Although it is not categorized as a technical case, the underlying investigation is based on technical documents produced by NRO engineers. For this investigation, the filil assisted with the following actions: (1) did ADAM searches for the document propert~ (3 Mls), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, {3) sent an e-mail to ADAMS IM and requested the "history" of two of the Mls (i.e. ML14106A344 and ML14097A146), reviewed wed the information in the case fife, (4) determined" " actually submitted the document in ADAMS (i.e . ...l(b_)(_?_)(C

_ )_ _ _ _~,

( )(7) . .

(5) discussed "why (Cl ould leave individual names in the document that was publicly released, and (6) research the policy/procedures for the "Open Door Policy when meeting with a Commissioner.

(b )(?)(A),(b )(?)(C)

(b)(?)(A),(b)(7)( C)

(b)(7)(A) ,(b)(7)(C)

(5) Case 13-042, Fort Calhoun Proactive Initiative. Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically,. 0/G should attempt to determine why the NRG in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

(6) Case 15-028, Indian Point. OIG management team, On April 8, 2016, had a phone conversation with P. BLANCH to review the 7 questions BLANCH asked in t ebruary 2016 (b) ,.,,-e-=,...,..,,.,--,

letter to Mr. BELL. (7) invited SAl(b)(?)(C) I- A separate case is in the process of being (C) initiated. To date, t e A has not been named.

(b)(7) ~

CA (C) , and~met to discuss the status of this case. CA reported that he is addressing 2 specific issues (1.e. the tank contents and 2.206 process and lack of a formal letter) and has

been reading/following all the additional information BLANCH has summited to OIG since Fall 2015. This includes the 36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

ITen Additionally, P Blanch calledllci.J(see Chron note) and reported that he was planning on sending Mr. BELL a letter d (i.e. letter was submitted in March 201 requesting an investigation into (b)

NRC's inadequate oversight at Indian Point. Thereafter, (7) and Deputy AIGI had a phone conversation with BLANCH ( see below for spec Wies of th c II.) 11~l Iis waiting for this separate case to be opened and plans to support the named CA. (C (7) Case 15 013, St. Lucie MSIV CDBI Inspection No new update. The following was reported in the last quarter summary, "St. Lucie MSIV failure after Component Design Basis Inspection (CDBI) , Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his i nvestigation."

(8) Case 15-029, Pilgrim SRV CDBI Inspection. No new update. The following was reported in the last quarter summary, "Pilgrim SRV failure after a CDBI. Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a gu;de during his investigation."

has supported CA l(bJ(YJ(CJ

~w1 (9) Case 16 O!~ NRC misuse of Funds. ~ ~th this investigation. assisted by: (1) contacted NRR technical advisor and received confirmation from the staff a both rules that were described in the FRNs have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the Information gathered for this case. The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates. The CA is currently pursuing

1

:~~t::;;;::c Inappropriate process for digital control RIS. fil},as supported SA ICb)(?)(C) !with this investigation. SA has submitted a CTF memo which is pending. ~

assisted by; (1) participated in the interview of the PM, (2) reviewed material for the 1/22/16

public meeting, (3) discussed this area during a meeting with Dave Lochbaum which is documented in a MTF, and (4) met with l(b)(7)(C) l(current ~ nd r (?)(C) r )(o/)(C) ~- He explained the situation with ex-brancbirnl1ates1..t-o-t~hi~s-c-a-se- .-l-n _ __,

Magnum are several Chron Notes documentinlcr'l support activities.

(11) Case 16 016, Indian Point Tritium Leak 1'nro-1Hudson River~12l lis supporting c ~ (b)(?)(C) with this case. On April 6, 2016, CA and1:~~1had a planning/update meeting on April 6, 2016 and discussed the following: (C A. The allegation from, U.S. Senator Kirsten Gillibrand, requested OIG to:

While I know that the NRG has not yet completed its investigation into the specific cause of the most recent leak, it has been brought to my attention that the leak most likely occurred during preparations for the next refueling outage, while waste stream water was moving to the waste storage tank. More troubling are reports that Entergy personnel were aware of related equipment problems as early as 2014, but failed to adequately repair or replace the equipment .... .. Additionally, I would like information on whether the NRC's resident Inspectors at Indian Point we aware of the malfunctioning equipment which caused the most recent leak, and whether it was flagged as a potential issue at any point prior to the discovery of the leak, and why the decision was made not to repair it in 2014.

8. CA and~ reviewed Indian Point (IP) prior inspection reports and learned that one of the 201 ~ spection reports referenced the sump pump being questioned in the allegation. Therefore, In NRC Inspection Report dated March 13, 2011 , OIG learned from the report that, (page 10): the NRC noted that "sump pumps required for mitigation of internal and external flooding were verified by licensee to be satisfactory. Also it stated, "the inspectors reviewed a sample of flood protection equipment testing and maintenance. Documents reviewed by the inspectors are listed in the Supplemental Information Attachment to this report .In Supplemental Information, A-3, Condition Reports, the NRC referenced: CR-IP2-2011-1717, 28 Sump Pump in Fuel Storage Building (FSB)Testing Issues, 4/10/11.

C. On March 4, 2016,!(b)(?)(C) !e-mailed to CA that "the name of the sump pump at IP2, thereby contributing to the tritium leak from the reverse osmosis unit is "FSB Sump Pump 28."

D. The inspectors that performed the March 13, 2011 dated inspection were: (b)(?)(C) and (b)(?)(C) (RI). 1~~57) lis currently (b)( )( and (b)(?)(C) is in NRO (b)( )(C)

E. The (b)() ent to assist with the February 2016 inspection was l(b)(?)(C)

(b )(?)(C) from Division of Reactor Safety.

F. Reviewed Fukushima Lessons Learned website for IP and found no noted concerns with sump pumps.

Next Steps: IDb)

1. lntervie111 (b)(?)(C) - for background information (7) to generate questions for CA to ask)

2. lnterive (b)(?)(C) - the inspector who assisted with c inspection in March 2016

3. Request NRC e-mails fo~(b)(?)(C) IDRB), l(b)(?)(C) land ,...,l )(=7)....,..,

(b..... (C,.,....

)- I (inspector).

4. Plant visit to review Corrective Actions.5. Based on items 1-4 above, lnterviewj(b)(?)(C) 7

~~)< ) DRB).l(b)(?)(C) Ian9(b)(?)(C)  !(inspector)

(b)

(7)

On April 7, 2016, CA and (C) interviewedl(b)(?)(C) I* A MTF of the interview is in the case file.

Im, ladded Inspection Procedure (IP) 71111 .01 "Adverse Weather Protection" and the March 2011 Inspection Report to the case file ~~~ identified that "corrective action records" are required for review per IP 71111 .01 . (C)

(12) Case 16 014, Fukushima FOIA ~2 upported c Aj(b)(?)(C) lby setting up and participating in a meeting with the alleger, Dave LOCHBAUM. Based on the discussion, LOCHBAUM might withdraw his allegation. ~~~ prepared a MTF with details and analysis from the meeting. (C) 16J (7)

(C)

Durina this oorlod the reviewed the followina alleaatlon assigned to her:

(b)(7)(A),(b)(7)(C)

(b)(?)(A),(b)(7)( C)

(b)(7)(A),(b)(7)(C)

(3) Allegation 15-07582- UFSAR Public Availability in ADAMS. ~ iscussed this allegation with alleger, David LO,UM. The NRC reversed a SEffiased on (b)

LOCHBAUIM's request. To date, (7) s still working with LOCHBAUM to see if his concern with UFSARs has been resolved. For pie, DC was just added to ADAMS in March 2016k which is approximately 1 year since it was docketed in Still monitoring delays in making FSAR publically available.

(4) Allegat1on 14 07379 - Chrystal River Seismic Concerns. Still working on Closure Memo. No new update. Has been delayed due to priorities. WIii try to get to Joe by Nov 10th COB. Region ll's Allegation Review Board's review of seismic concerns with Chrystal River -

The alleger believes the numerous engineering concerns he proved to Region II were not (b)(7)(C) adequately addressed. _ ____,reviewed the information provided by the alleger and identified a potential gap in the review process by the engineer who was tasked with assisting with this 7

a llegation. (b)(?J(C) met with engineer to understand the process the engineer followed. (blf l(Cl is still in the process of developed a closure MTF for this allegation.

(b)(?)(A),(b)(7)(C)

(b )(7)(A),(b)(7)(C)

Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 Region IV counterpart meeting. See Chron note for further details. appears NRC reviewed in ROP inspection this component that ultima; failed. MTF will be drafted if research indicates NRC had a potential lapse in oversight. ~~) will follow-up on this allegation next quarter. (C (b)(4), (b)(?)(A), (b)(?)(C), (b)(?)(D)

(b)(7)(A),(b)(7)(C)

(b)(4), (b)(7)(C), (b)(7)(D)

(b )(4 ), (b )(?)(A), (b)(?)(C), (b)(7)(0)

Durin this review riod m ommunlcated with the followin Stakeholder Grou s:

(1) Dave Lochbaum - On January 20, 2016, Dave Lochbaum was at NRC HQs and met with OIG I['; r nd SA l(b)(?)(C) 1. The following items were discussed:

• Cancer Study - Industry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they

will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing ~ction (i.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk, All in all, the results did not have any statistical outliers they were deemed significant but the study did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aware of any "international" or "regulatory changes" related to this s.tudy as described in Case 16-013.

• The Special Interest Group guru for radiation dose isl.... _l_ ____,I Dave will e-mail (b-)(7-)(C his contact information.

• Dave is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRC would require "evaluations" - not simple function testing - in order to demonstrate that equipment past its service life is still safe. The industry does not want evaluations to be used as a control point.

• Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

(2) Paul BLANCH - on March 17, 2016filland Deputy AIGI Had a phone conversation with Paul Blanch regarding the letter BLANCte to Mr. Bell in March 2016. He alleged NRC's oversight was not appropriate.~ notes from the meeting include:

A. BLANCH's top 3 issues: [1] Violation of MD 8.5 and 8.11 (2.206 Petition), [2) IP operating in an unanalyzed condition, and [3] from Blanch's letter... item #5. Buried (b)(7)(C) portion has never been analyzed. But does it need to be? OIG to ch~ RC said (b)(?)(Cl told him, "the above ground portion has been analyzed." PerE_J in 2008, it wasn't analyzed ...however, there was an allegation in 2008 about the gas line near the river...800 feet away..in response to that allegation .... NRC responded a rupture won't jepordize the safety structures. But...they didn't seem to analyze the buried portion (in 2010 Paul did a petition) told him they just analyzed the above ground portion.

B. Paul said, "We can conclude the N*R c has not done an adequate risk assessment.. ..operating in an unanalyzed condition. We can't direct the AGENCY but we could send to the EDO and Commission and hopefully they will take action.

(b}

C. Dave Lochbaum - On March 10, 2016, (7) met with LOCH BAUM. At the meeting, (C)

LOCHBAUM shared the following lnforma 10n:

• He met with the FOIA office regarding his concern with Fukushima FOIA requests. A separate MTF has been developed regarding this topic.

• He discussed his current project which is researching, reviewing, and understanding why NRC has a large number of RAls. He believes industry is putting pressure on NRC to reduce RAls. However, LOCHBAUM is looking into10 CFR 50.9 to see if licensees are really the ones who need to be accountable for providing complete and accurate information.

• He is waiting for NRC to put all UFSARs back in ADAMS per SECY.

During this period,ll2J ~ supported OIG efforts to:

l( I .

_ _____, prepared a presentation for DOE l(::>)(7)(C}

(1). DOE OIG. ._b)(7)(C) _ _ _ _ _ _ _ _ The I presentation focused on NRC's mission with "DOE/NRC common connections" identified throughout the presentation. The link to the presentation is listed below.

(b)(4), (b)(7)(C), (b)(7)(D)

(b)(7)(A),(b)(7)(C)

(b)

(3) Training for Special Agents presented the DOEINRC power point to l(bl(7)CC) !per Tl 's (7) request on April 11, 2016 (C)

Part 2 of Reactor Concepts Training was completed on February 4, 2016. All the training material is included in a chron note within 13 027.

Prepared an update to the SA Technical Training Plan and presented during February OIG Strategic Planning Meeting.

Second and third quarter training includes S-201, Materials Controls, Security Systems and Principles course (taught by TTC Staff) and ADAMS training (in iLearn) i~! is working with Team Leaders to get folks registered and completion of these courses. (C)

( 4) Interface w~th OIG Audits - ~

~was briefed by l(b)(?)(C) !regarding the 50.59 audit OIG is conducting. W,Jsuggested that Audits review all the Special Inspections pertormed in the last few years and e ermine if the equipment that failed was (1) previously inspected by NRG and/or (2) recently modified under 50.59. Also,I12) r uggested Audits review the last 3 years of LERs and determine the same. Hence, did the equipment that failed was (1) previously inspected by NRC and/or (2) recently modified under 50.59. 1!2 !also provided Information regarding "additional guidance" industry utilizes. Meaning, NEI 96 07 is not the only guidance used by Licensees.mflagree to obtain the name of the additional guidance. Overall, it appears this audit is leading ~ any lose ends that appear to impact the effectiveness of NRC oversight of 50.59. Also, 50.59 audits might be eliminated per Project AIM.

Planned Investigative Activities:

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytics Other Documents:

DOE Presentation:

C:\Users\TXS7\Documents\XPMigratedFolders!(b)(?)(C) hNRC_DOE_March 15 2016.pptx In novatlve Activities (b)

( 1). (7) working on a global summary of AIGl's use to brief NRC Offices.

(C)

Interviews:

A . (b )(?)(A),(b)(?)(C)

B.

I (b)(7)(C) I February 5, 2016 Project 13 027 To date 1st and 2nd Quarter 2016Summary The latest updates from the Quarterly Case Summary Report and last update are In Green. The color red represents the January 22, 2016 update.

Case Update:

(b)

=::..:.:.:.~=...c.:~ri=o=-di....:t:.:..:h~

e (7) cases:

(C 1 Case 16 001 , SA Is preparing to interview and has discussed his background research with (b)(7)(C) nd SA met to discuss. SA is reviewing e-mails and hasn't come across anyt~ hat 1s su stantial. Began discussions on questions that will be asked during the Interview. (CJ and SA met to discuss case. Although not categorized as a technical case, the underlying investigation is based on technical documents produced by NRO engineers. During this working meeting, we performed the following action: (1) did ADAM searches for the document properties (3 Mls), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the Mls (i.e. ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined "who" actually submitted the document in ADAMS (i.e. l(b)(?)(C) p. and (5) discussed potential "next" investigative steps. . -

As a result of this meeting, theWiJhas the following action items:

1. Develop a MTF for the "Ope oor Policy" as it relates to the disposition of material prior to a meeting with the Commission. Completed

2. Develop a MTF for "Pre-Decisional Information" as it relates to the release of information for this case.

(b )(7)(A),(b)(7)(C)

(b)(?)(A),(b)(7)( C)

(b)(7)(A),(b)(7)(C)

(5) Case 13-042, Discuss this case with Joe. Fort Calhoun Proactive Initiative. Continued to supporting this case by: (1) Took the action to do an extensive analysis of the issues found during the 0350 inspection and determine if NRC had reviewed any of these concerns in prior inspections and prepared a MTF, (2) Took the action to review all the actions/events related to the 480 Vac breaker fire and wrote a MTF, and (3) Assisted with the Closure Memo which recommended the following, which was based on the MTFs developed for this case: OIG should consider initiating an investigation focused on the 480 Vac breaker fire and relating'corrective action program problems. OIG should attempt to determine why the NRC in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports. In addition, Investigations should brief OIG Audits on its obseNation that 28 of the components identified as problematic through the FCS 0350 inspection process had received ROP oversight prior to the start of the 0350 inspection process, yet remained problematic. This information may be useful to Audits in connection with its FY 2016 Audit of NRC's Reactor Process. It is recommended that this proactive initiative be closed to the files of this office based on the above suggested courses of action.

(6) Case 15-028, Sent CA an article from thee Reader His response was. "I already had obtclined some previous Chairman correspondence relating to these issues and some previous s1m1lar material from Accufacts, both of whicll I'm in the process of reviewing, so I'll add this material to that." Keeping abreast of the situation, however, no interactions with the CA.

Concerns with potential material in Indian Point tanks and inadequate allegation process.

Supported the Case Agent by attending a meeting scheduled by the AIGI. Continue to take the initiative to be monitor the alleger's (Paul Blanch) concerns. [See discussion on Paul Blanch below.)

(7) Case 15 013, No new update. CA informed hat case is on hold due to priority case. St.

Lucie MSIV failure after Component Design B nspection (CDBI). Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investi ation.

(b (8) Case 15-029, No new update CA informed [2) hat case is on hold due to priority case. No help requested from CA. Pilgrim SRV failure a CDBI. Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation.

(9) Case 16 013, CA and ~ met to discuss. CA informed!Wl.hat he is reviewing contract mformat1on. rcrrlpulled Fe~ I Register Notices to see wha~ included in the 2 pre-ruling making docum~fas. The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates. The CA is currently pursuing a copy of the ~b ) tract. nb)

(10) Case 16-012, CA informed (2 that his MTF is with OIG management. [2) nd SA }ID interviewed the PM. Based on in ormation reviewed, it appears the RIS pro sis being [2> CA attended and also re~ ed a transcript of the public meeting - which was provided by PM on 1/22/16. Also, the 1~>' nd SA discussed this area during a meeting with Dave Lochbaum which is also docume in a MTF. Based on all information gathered, the CA ~ s velo ed a CTF memo. (b)(7)(C) nd S (b)(7)(C) met with (b)(7)(C) (current (bl( )( and (b)(?)(CJ (b ( l l e explained the sI ua I0n w1 h ex-branc as I rela es

'rn"mr.5'"'Cl3'S'E!".'"Uiaa:mr.3'g'TrnnTFi.....,'3'Tltr.5:'F(developed questions and steps for the investigative roJect are several relative documents for review.

---

1 he (C) reviewed the followin

• ned to her:

(b)(4), (b)(?)(A), (b)(?)(C), (b)(?)(D)

,~ )(7l(A), (b)<7)(C)

(b)(7)(A),(b)(7)(C)

I informed 1f UF$ARs are blm,glavailable Still working ?wf (3) Allegation 15-07582 J r lc;poke with l OCHBAUM and LOCHBAUM is keeping(b)(?)(C) ave Lochbaum to see if his concern with UFSARs Is solved. DC seems to be an outlier that ~) and Lochbaum are working through.

Delays in making FSAR publically available. This cone s being addressed within the merits of Case 15-007. Next step is to develop a close to file memo.

(4) Allegation 14 07379 - Working on Closure Memo. Has been delayed due to priorities. Will try to get to Joe by Nov 10th COB. Region I l's Allegation Review Board's review of seismic concerns with Chrystal River - The alleger believes the n merous engineering concerns he proved to Region II were not adequately addressed. (b)(?)(C) reviewed the information provided by the allege, and identified a potential o~i\?Jhe( eview process by the engineer who was tasked with assisting w*

• legation. < < l met with engineer to understand the process the engineer followed. (bl(7 l(C) is still in t e process of developed a closure MTF for this allegation.

(5) Allegation A15 07758 - This allegation was turned into Case 16-013. On 12/21/15, SA

!{b){7){C) l and l(b)(?)(C) l dis,~ ~~ his allegation~ reviewed the 6 documents cited in the allegation. Engineering Intern (b)(?)(C) developed a ~ that outlines the 6 documents and summarizes the subject of the documents. The first 5 documents are related to "Radiation Protection" and the 6th document is related to "Power Plant Effluents." Each of these subjects

~~~~~ed rule published in the Federal Register Notice in~:.e~.lol..f"015, respectively.

is currently researching the status of these rules. (b)(7)(C) has reached out to

,..__ _ _.....__ _ _.;......,for the EDO) for a status of the 2 cita ions 1.e. 9FR43284 and Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 Region IV counterpart meeting. See Chron note for further details. appears NRC reviewed in ROP inspection 1his component that ultimately failed. MTF will be drafted if research indicates NRC had a potential lapse in oversight.

(b)(4), (b)(?)(A), (b)(?)(C), (b)(?)(D)

(b )(4)

(b)

Durlna this review neriod (7) communicated with the followlna Stakeholder Grouos:

~

(1)~ochbau - nuary 20, 2016, Dave Lochbaum was at NRC HQs and met with

~ and SA (b)(?)(C) The following items were discussed:

• Cancer Study - Industry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (I.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk. All in all, the results did not have any statistical outliers they were deemed significant but the study did identify some high rate sites. This study was funded by NRG and conducted by NAS. Dave is not aware of any "international" or "regulatory changes" related to this study as described in Case 16-013.

• The Special Interest Group guru for radiation dose is l(:i)(7 l(Cl ~ Dave will e-mail his contact information.

• Dave is at HQ today for the public meeting on the RIS for Aging Components. H~

agrees with NRC's position and hopes they don't change ,t. Per Dave, the NRC would require "evaluations" - not simple function testing - in order to demonstrate that equipment past its service life is still safe'. The industry does not want evaluations to be used as a control point. *

• Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

(2)~chbaum - On Nov 19, 2015, Dave Lochbaum was at HQs for public meetings.

(bl(7)(C) and Dave met and discussed:

1. oc aum's concern with G * ' ecurit FOIA. He believes NRC has sent mixed messages and is working with (b)(7)(C) and (b)(?)(C) o fix.

2. Lochbaum attended a Projec ne ing. He had no comment.

3. Lochbaum was surprised the Commission voted against the "Cummulative Effect of Regul~tion" that Licensees/Industry proposed.

4. Lochbaum discussed a concern - that he and other special interest groups are currently researchirng - is the NRC cancelling phase II of the NAS cancer study. He mentioned that (b)(7)(C) is considering submitting a 2.206. The NRC is saying the project was cancelled ue I but Lochbaum and other special interest 9rr~~scf ri wondering if it was cancelled due to "bad news." Lochbaum agreed to inform ( ( )( once more information is available.

5. Lochbaum discussed a study he conducted of Enter 's reactors in the "merchant market" e the "regulated market." He will send analysis t (bl( )( )

On December 1, 201sj(b)(?J(CJ !reviewed his study (item 5 and determined, "that "utility owned" had 3 occurrences for quarters in column 3, 4 or 5, versus "wholesale commodity owned" had

38. Even though the number of ownerships was 5 versus 7, it's still a pretty big discrepancy."

~

During this period,lidjsupported OIG efforts to:

(b)(4), (b)(?)(C), (b)(7)(0)

(b )(7)(A),(b)(7)(C)

(b )(?)(A), (b )(7)(C), (b )(7)(0 )

I(b)(7)(C) January 22, 2016 Project 13 027 T o date 1st .and 2 nd Quarter 2016Summary Updates from the Quarterly Case Summary Report are in Red.

Case Update:

(b)

=-===-=.:.:.:.=;..c.::.:.r.:..:lo;,.;d~th:.:..:e::.i(7) ort to the s

• ent for the followin cases:

(b) C (1) Case 16 001 , ~) nd SA met to discuss. SA is reviewing e-mails and hasn't come across anything *s su s antial. Began discussions on questions that will be asked during the interview. [~~(c and SA met to discuss case. Although not categorized as a technical case, the underlyin stigation is based on technical documents produced by NRO engineers. During this working meeting, we performed the following action: (1) did ADAM searches for the document properties (3 MLs), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the MLs (i.e. ML14106A344 and ML14097A146), reviewed wed the jnfacmatian io the case file, (4) determined "who" actually submitted the document in ADAMS ~(bl(? )(C) ~.

and (5) discussed potential "next" investigative steps.

(b)

As a result of this meeting, the l2) has the following action items:

1. Develop a.MTF for the "Open oor Policy" as it relates to the disposition of material prior to a meeting with the Commission. Completed 2 . Develop a MTF for "Pre-Decisional Information" as it relates to the release of information for this case.

(b )(7)(A),(b)(7)(C)

(b)(7)(A),(b)(7)(C)

(5) Case 13-042, Discuss this case with Joe. Fort Calhoun Proactive Initiative. Continued to supporting this case by: (1) Took the action to do an extensive analysis of the issues found during the 0350 inspection and determine if NRC had reviewed any of these concerns in prior inspections and prepared a MTF, (2} Took the action to review all the actions/events related to

the 480 Vac breaker fire and wrote a MTF, and (3) Assisted with the Closure Memo which recommended the following, which was based on the MTFs developed for this case: 0/G should consider initiating an investigation focused on the 480 Vac breaker fire and relating corrective action program problems. OIG should attempt to determine why the NRG in 2009 did not cite Fort Calhoun for the 480 Vac and refated condition reports. In addition, Investigations should brief 0/G Audits on its obseNation that 28 of the components identified as problematic through the FCS 0350 inspection process had received ROP oversight prior to the start of the 0350 inspection process, yet remained problematic. This information may be useful to Audits in connection with its FY 2016 Audit of NRC's Reactor Process. It is recommended that this proactive initiative be closed to the files of this office based on the above suggested courses of action.

(6) Case 15-028, No new update. Keeping abreast of the situation, however, no interactions with the CA. Concerns with potential material in Indian Point tanks and Inadequate allegation process. Supported the Case Agent by attending a meeting scheduled by the AIGI. Continue to take the initiative to be monitor the alleger's (Paul Blanch) concerns. [See discussion on Paul Blanch below.]

(7) Case 15 013, No new update. CA informed~ that case is on hold due to priority case. St.

Lucie MSIV failure after Component Design Ba~nspection {CDBI). Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his irwe;iation.

(8) Case 15-029, No new update CA informed (~ that case is on hold due to priority case. No help requested from CA. Pilgrim SRV failure a er a CDBI. Provided the Case Agent with 2 MTFs that identify the areas*NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investi ation.

(b)

(9) Case 16 013, CA and et to discuss. l2i ulled Federal Register Notices to see what was included in the 2 pre- g making docum . The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates. The CA is currently pursuing a copy of the contract.

(10) Case 16-0 1 2 , ~nd SA interviewed the PM. Based on information reviewed, it appears the RIS process 1s being followed. PM provided information for a public meeting on this subject (January 20, 2016). The CA attended and also req? ! :d a transcript of the public meeting - which was provided by the PM on 1/22/16. Also, the rc> and SA discussed this area during a meeting with Dave Lochbaum which is also document a MTF. B~~~......._,

information athered the CA has veloped C b 7 c (b)(7)(C) met with (b)(7)(C) (current (b)(7 J(Cl and (bl(7 J(CJ . He explaine e s, ua ,on with ex- ranc as it re ates to t rs case. see agnum 7 c nd SA developed questions and steps for the investigative plan. Also inrub ) Magnu oject are several relative docume or review. (?c)

(b)

Durln this eriod the (2reviewed the followin

(b )(7)(A),(b)(7)(C)

(3) Allegatlon 15-07582 - Still working with Dave Lochbaum to see if his concern with UFSARs is solved. DC seems to be an outlier that \g(7) nd Lochbaum are working through. Delays in making FSAR publically available. This rn is being addressed within the merits of Case 15-007. Next step is to develop a close to file memo.

(4) Allegation 14 07379 - Working on Closure Memo. Has been delayed due to priorities. Will try to get to Joe by Nov 101h COB. Region ll's Allegation R,eview Board's review of seismic concerns with Chrystal River - The alleger believes t ~ o u s engineering concerns he proved to Region II were not adequately addressed. ~ evlewed the information provided by the alleger and identified a potential ga in the review process by the engineer who was tasked with assisting with this allegation. (b)(7)(C) met with engineer to understand the process the engineer followed~(b)(?)(C) ts still in the process of developed a closure MTF for this allegation.

(5) Allegation A15 07758- This allegation was turned into Case 16-013. On 12/21/15, SA nb)(?)(C) 7 and !(b)(?)(C) !discussed this allegationF,Wl7reviewed the 6 documents cited in the allegati6n. Engineering Intern (b)(?)(C) developed a la5re' that outlines the 6.documents and summarizes the subject of the documen s. The first 5 documents are related to Radiation Protection" and the 6th document is related to "Power Plant Effluents." Each of these subjects had a ro osed rule published in the Federal Register Notice in 2 14 n 2015, respectively.

(b)(?)(C) is currently researching the status of these rules. (b)(?)(C) has reached out to

7 l(b)(?)(C) (b-)(-l(-Cl_ __,l for the EDO) for a status of the 2 citations (i.e. 79FR43284 and U,_

80FR25237.,

Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 Region IV counterpart meeting. See Chron note for further details. appears NRC reviewed In ROP inspection this component that ultimately failed. MTF will be drafted if research indicates NRC had a potential lapse in oversight.

(b )( 4), (b )(?)(A), (b)(?)(C), (b)(7)(0)

(b)(7)(A)

(b)(4 ), (b)(7)(A), (b)(7)(C), (b)(7)(0) b)

Durina this review oeriod. (7) communicated with the followina Stakeholder Groups:

(C)

(1) Dave Lochbaum - OnTanuary 20, 2016, Dave Lochbaum was at NRC HQs and met with l(b)(?J(C) ~ nd SAl(b)(7)(C) ~ The following.items were discussed:

• Cancer Study - 1naustry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (i.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk. All in all, the results did not have any statistical outliers.they were deemed significant but the study did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aware of any "international" or "regulatory changes" related to this study as described in Case 16-013.

• The Special Interest Group guru for radiation dose isl(&)(?)(C) I Dave will e-mail his contact infonnation.

• Dave Is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRC would require "evaluations" - not simple function testing - in order to demonstrate that equipment past .its service life is still safe. The industry does not want evaluations to be used as a control point.

• Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

• ...,1,1,1~.A.l'chbaum - On Nov 19, 2015, Dave Lochbaum was at HQs for public meetings.

and Dave met and discussed:

1. 1 c..,.....-

au.....m's concern with GrAen Piece's ~Acuri FOIA. He believes NRG has sent mixed messages and is working wit~ l(7l(C) !and (b)(7)(C) to fix.

2. Lochbaum attended a Project AIM briefing. He a no comment.

3. Lochbaum was surprised the Commission voted against the "Cummulative Effect of Regulation" that Licensees/Industry proposed.

4. Lochbaum discussed a concern - that he and other special interest groups are currently researchjng - is the NRG cancelling phase II of the NAS cancer study. He mentioned that l(b)(7)(C) lis considering submitting a 2.206. The NRC is saying the project was cancelled due to funding but Lochbaum and other special interest grou s are wondering if it was cancelled due to "bad news." Lochbaum agreed to infer (b)(?)(C) once more information is available.

5. Lochbaum discussed a study he conducted a

• reactors in the "merchant market" e the "regulated market." He will send analysis t {b)(7J(C)

On December 1, 2015, (bJ(l)(C) eviewed his study (item 5 and determined, "that "utility owned" had 3 occurrences for qua ers 1n column 3, 4 or 5, versus "wholesale commodity owned" had

38. Even though the number of ownerships was 5 versus 7, it's still a pretty big discrepancy."

15)

During this period, (7) supported OIG efforts to:

Ill" (b)(4), (b)(7)(C), (b)(7)(0)

(b)(4), (b)(?)(D)

(3) Training for Special Agents - Preparing for Part 2 of Reactor Concepts Training.

Prepared an update to the SA Technical Training Plan and presented during OIG Strategic Planning Meeting Completed Part of Reactor Concepts Training. All the training material is included in a chron note within 13 027. Although a scenario was developed for the training -

which was based on an old allegation and included a developed template for technical case -

there was not enough time to have SAs do. It was determined to incorporate the scenario in part 2 of the Reactor Concepts training class to be scheduled next quarter.

Additionally, working on 2016 training plan. Met with AIGI and plan to have an updated plan by November 12, 2015. Planning *site visit to TTC to obtain training material for classes the l(bR7)7 plans to teach to SA. ~

(b)(4), (b)(?)(A), (b)(?)(D)

OFFICIAL USE ONLY

• ChronNote Prepared by: l(b)(7)(C) I0 //20/1016 Case

Title:

Special Project: NRC Case Number* C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification :

Origination Docllnk:

Date: 01/20/2016 Note TiUe: Dave Lochbaum Mt Note: On 1/20/16, SA ..,.,. (b"!',

)(=7)"""

(C""'"

) ...,and l(b)(7)(C) !met with Dave Lochbaum. Dave provided input on the following items:

1. Cancer Study - Industry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI . Industry believes they will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (i.e. LAR, License Renewal , etc.)

Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk. All in all. the results did not have any statistical outliers they were deemed significant but the s.tudy did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aware of any "international" or "regulatory changes" related to this study as described in Case 16-013. l(b)(?)(C)

2. The Special Interest Group guru for radiation dose is ...._ _ _ __, Dave will e-mail his I

contact information.

3. Dave is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRC would require "evaluations" - not simple function testing - in order to demonstrate that equipment past its service life is still safe. The industry does not want evaluations to be used as a control point.

4. Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

5. Potential l(b)(7)(E) Read Authorization: {Monitor), (All)

Allow Other Edltof-s: Edit Authorization :

OFFICIAL USE ONLY

(b )( 4), (b )(7)(A), (b )(7)(D)

OFFICIAL USE ONLY (5) Case 13-042, Fort Calhoun Proactive Initiative. Although a MTF was developed that recommending opening a case on the breaker fire, this case will not be opened due to the announcement that Fort Calhoun will be shutting down soon.

(6) Case 15-028, Indian Point (May 2015 Ltr to Mr. Bell). SSAl~~l(?) ~s handling this case independently as of the last briefing (April timeframe.) CA (b)f?) s determining if the fuel tanks (C) are empty.

(7) Case 15 013, St. Lucie MSIV CDBI Inspection. SSAl~~r) lis handling this case independently. No new update . The following was reported in the last quarter summary, "St.

Lucie MSIV failure after Component Design Basis Inspection (COB/). Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation ."

(8) Case 15-029, Pilgrim SRV CDBI Inspection. SSA~ ~} s handling this case independently. No new update . The following was reported in the last quarter summary, "Pilgrim SRV failure after a COB/. Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the GOBI inspection procedure that the Case Agent can use as a guide during his Investigation. "

(9) Case 16 013, NRC misuse of Funds. Case is closed to file ~~~) supported CAl(b)(?)(C) with this investigation.

(10) Case 16-012, NRC inappropriate process for digital control RIS . CA is closed to file .

~ suppor1<!d SA l(b)(7J(C) Iwith this lnvestigat~n.

(11) Case 16 016, Indian Point Tritium Leak into Hudson River.~ is continuing to support cAl!~,(7) lwlth lhis case. CA and ~~fet (July 28") lo discuss the transcript oi ~l<~<CJ I 1<0l(l)(C) 11:~lI (C

prepared a tee al presentat~n during the week of August 15* to OIG OFFICIAL USE ONLY 3

OFFICIAL USE ONLY management to describe the tritium situation and to create MTFs for the technical analysis and policy concerns. 1m 1is awaiting for CA to set up interviews with Resident Inspectors in October.

(C (12) Case 16 014, Fukushima FOIA. Case is closed to file .Im! supported CAl(b)(l)(C) Iby setting up and participating in a meeting with the alleger, Oa~OCHBAUM.

(b )(7)(A),(b)(7)(C)

(b )(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 4

OFFICIAL USE ONLY l(b)(7)(A)

(b)

(15) Case 16 035, Conflict of Interest, (7) assisting CA by acquiring and reviewing ADAMS (C) dqcuments for concurrency by subjec w1 in the last 3 years. A lso, provided regulation and Management Directive that NRC employees are instructed to follow when seeking outside employment. Also did research on 5 companies and their nexus to NRG.

(16) Security Project,~ completed a MTF for SSA ....

l(b_)(_7)_(c_)_......,lregarding INPO's reports related to security. Ej (b)(7)(A),(b)(7)(C)

(18) Case 15 041 , l(b)(?)(C) Ientered containment . ~ and l(b)(?)(C) lmet with OGG and requested clarification of NRC policy/procedures. OGG responded and OIG is currently evaluating.

(b)

-=.:....:..:..:.=..:..:..:.....c..::.;r:...:.;io::;..;:d::..i....:ath:.:.:e~(7) reviewed the followin (C)

(1) Allegation A15 07758- This allegation was turned into Case 16-013.

{2) Allegation l(b)(?)(A) 1-This allegation was turned into Case (b)(?)(A)

(b)(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 5

OFFICIAL USE ONLY r b )(7J(AJ,(b)(7)(C)

( 4) Allegation A 16 07991 .f i leviewed this allegation and recommended it be closed. As stated in the chron note, "B on review of the information submitted , the alleger has 3 areas of technical concerns within the SONGS 50.59 document for the replacement steam generator.

They are: (1) ATHOS computer code, (2) FIT-Ill computer code, and (3) the value for the hot steam temperature (i.e. Thot). For area of concern (1), OIG clarified with NRC Research that ATHOS is a code used by the NRC for thermal-hydraulic analysis that is not considered safety significant since the secondary side of steam generators are bounded by the steam generator tube rupture technical specification . Concern areas (2) and (3) were reviewed in Case 13-006 by two NRC experts."

(b)(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 6

OFFICIAL USE ONLY

( b)(7)(A),(b)(7)(C)

(5) Allegation 14-07713- Management Disregard of NRC Inspection Manual Procedure .

~~f) reviewed the documents related to the FERMI security inspection in which the Licensee provided additional information for the proposed violation past the 30 days due date. NRC management instructed the inspectors to consider the information . However, the additional information did not change the outcome of the violation. CTF memo is being developed.

(b)(7)(A),(b)(7)(C)

(b)

(7) Allegation 15-07582 - UFSAR Public Availability in ADAMS. ~2) discussed this allegation with alleger, David LOCHBAUM~irnd LOCHBAUM disc ' uss this concern on a regular'basis. To date, LOCH BAUM said c ificant number of UFSARs are now publicly I

available but not all. LOCH BAUM is still monitoring andl~~~ will continue to keep abreast of the situation.

(8) Allegation 14 07379 - Chrystal River Seismic Concerns. Working on Closure Memo.

Proactive Reviews:

r )(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 7

OFFICIAL USE ONLY (b)(7)(A),(b)(7)(C)

(b)(4 ), (b)(7)(C), (b)(7)(0 )

(3) Economic Espionage: No assistance with CA during this quarter.

(b)

Durin this review eriod (7) communicated with the followin Stakeholder Grou s:

(C (1) Dave LOCHBAUM ontinues to have periodic phone conversations with LOCHBAUM and reads LOCHBAUM's correspondence with NRC as LOCHBAUM copies Im, Ion many documents submitted to NRC.

OFFICIAL USE ONLY 8

OFFICIAL USE ONLY (2) In July 2016,~ met with Dave LOCHBAUM prior to the Commission Meeting in which Dave LOCH BAUM was a guest speaker. LOCH BAUM shared his views of the NRC safety culture. During LOCHBAUM's meeting with OIG, he described several areas within the I

2.206 petition process that Stakeholders are concerned about.l(b)(?)(C) arranged for 2 OIG audit personnel to join the meeting with LOCHBAUM.

~

During this period,[tj supported OIG efforts to:

(1) Attended the Commission Meeting on July 26, 2016, titled, "Meeting with NRC Stakeholders." During the meeting, the subject of FLEX equipment" was often discussed.

I The information regarding FLEX equipment was shared with SSAl~~f) because it has applicability to his l(b)(?)(A) l r l(7XAI.(b)(ll(CJ (3) Training for Special Agents - Prepared an update and summary to the SA Technical Training Plan and plan to AIGI for fiscal year 2017. Prepared and presented technical training on Industry Events during the Sept g'hAll Hands meeting.

(4) Interface with OIG Audits - 11~~ l talked to Paul about 2.206 petition audit for next year. Also talked to 2 audit folks on Paul's team. Provided ideas and background on Stakeholder's concern with 2.206 petition. Shared notes from 2013 meeting with Stakeholders.

(5) Interface with OIG Audits I met with ASME audit team twice and introduced the audit manager to a N'RC staff heavily involved with ASME code committees. I~~?) I and Audit Manager have another meeting set up for Sept 7, 2016.

(6) Interface with OIG Audits - Materials Teams -~met with the Material's team to items related to NRC's oversight of material exports, 11~l 1*hared past and current (C

OFFICIAL USE ONLY 9

OFFICIAL USE ONtV investigation/allegations regarding this subject. The audit team will be reaching out I

loI~~l once the team has determined the scope of the audit.

(C (7) Obtained the presentation material discussed in the April 11, 2016 NEA newsletter regarding, "NEA Semin~r on Lessons Learnt from the Waste Isolation Pilot Plant (WIPP)." Currenlly,l~ Jls planning to discuss with AIGI the next steps.

The seminar summary ates:

Recognizing the importance of safety culture and the impact of managerial and human factors on safety performance in the management of radioactive waste, the NEA held a seminar on 31 March 2016 to examine the lessons learnt from the accidents that occurred at the Waste Isolation Pilot Plant (WIPP) in 2014. Located in southeast New Mexico, the WIPP is the only deep geological repository for permanent disposal of transuranic waste in the United States. In February 2014, two isolated events- a fire and a radiological release- took place at the WIPP, triggering a rigorous accident investigation process. The NEA seminar reviewed the danger of complacency in the workplace and discussed means to create a safety.focused organization. The meeting discussions also revealed the effecti veness of social media as a communication tool. Participants underlined that emergency communications need to be open and transparent with the public in order to be effective and efficient."

Planned Investigative Activities:

(1) Continue supporting the Case Agents as described above .

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Contin ue to support the initiative to Improve data mining and analytics Interviews Conducted During Reporting Period :

07/04/201 ib)( ( )

07/01/201 09/29/201 08/25/201 07/27/201 Memos to Ale Prepared During Reporting Period :

OFFICIAL USE ONLY 10

OFFICIAL USE ONLY 09/13/2016 Case l(b)(?)(A) 08/15/2016 Case 16 016 08/11/2016 Case 16 016 08/11/2016 Case 16 016 08/11/2016 Case 16 016 08/05/2016 Case l(b )(7)(A)

Other Documents:

1. Technical Briefing - Case l(b)(?)(A)

2. Technical Briefing- Case 16 014

3. Technical Briefing - Case 16 012 Additional lnfonnation:

Engineering Intern:

Tasks:

1. r )(7)(A)

2. Case 16 032 - MTF for USC Article, "Seismic Shift,"* Completed* Sent to TL and CAs on June 7 2016 TL electrooicall a roved - awaitin si ned co ?

3. (b )(7)(A)

4. Case 16 032 - MTF for IMC 12 5 an ppen to TL and CAs on June 13. 2016 - awaited TL review.

5, (b)(7)(A) 6.

7.

Reviewer Comments:

Request Review:

l(b )(7)(E) Read Aulhonz.atlon: (Monitor], [All]

Level I Approval.

Level 2 Appro1*al: Approved Joseph A McMillan 10/12/2016 09 10:47 AM OFFICIAL USE ONLY 11

OFFICIAL USE ONLY Case Summarv Report Prepared by:I (b )(?)(A) I 06/30/1016 Case Number & C 13 027 Special Subject OIG special project: Self-Title Project NRC lnitiated Regulatory Oversight Date Opened 04/01/2013 Due Date 09/30/2016 Team AIGI Case Agent  !(b)(?)(C) fNRC Report for Period 06/30/2016 RePOrt Type* Initial Ending*

Origination 0 ocllnk: t l Allegation Facts:

l(b)(?)(C) !Project Update Investigative Plan:

OIG special project to strengthen NRC's efforts to protect public health and safety and the environment by proactively monitoring agency technical and regulatory processes, nudear industry trends, trade press, as well as other sources to identify potential problematic areas in NRC regu latory oversight of licensee. This special project is a continuation of a previous project, OIG Project case number 10-12.

C ase Update:

rd During the 3 quarter of fiscal year 2016, the following actions were completed:

(1) Case 16 001; NRO Pre-decisional Release of lnformatlon:~ assisted the CA l(b)(7)(C) lwho is assigned to this case. Although it is not categorized as a technical case, the underlying investigation is based on technical documents produced by NRO engineers . For this I

investigation, the] p, assisted with the following actions: (1) did ADAM searches for the document prope Ies (3 MLs), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the Mls (i.e. ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined "who" actually submitted the document in ADAMS (i.e. l(b)(?)(C) ~*

(5) discussed "why" BCs would leave individual names in the document that was publicly released, (6) research the policy/procedures for the "Open Door Policy" when meeting with a OFFICIAL USE ONLY 1

OFFICIAL USE ONLY (b)(7)

Commissioner, and (7) coordinated conversations with CA fo (C) to ensure communication and alignment between cases .

(b)(7)(A),(b )(7)(C)

OFFICIAL USE ONLY 2

OFFICIAL USE ONLY (b )(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 3

OFFICIAL USE ONLY (b )(7)(A),(b )(7)(C)

(5) Case 13-042, Fort Calhoun Proactive Initiative. Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically, 0 /G should attempt to determine why the NRG in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

(6) Case 15-028, Indian Point. OIG management team , Im:] is working with CA. P BLANCH was interviewed in June and OIG is currently conducting a confirmatory analysis to validate BLANCH's technical allegations regarding inadequate calculations by NRC staff. Additionally, during this quarter, on April 8, 2016,Im,FIhad a phone conversation with P. BLANCH to review the 7 questions BLAN CH asked in ttie ebrua,y 2016 letter to Mr. BELL. li'!~linvited SA l(b )(?)(C) I- A separate case is in the process of being initiated . To date, c e CA has not been named.

CA ~ . and ~ met to discuss the status of this case. CA reported that he is addressing 2 specific issues (i.e. the tank contents and 2.206 process and lack of a formal letter) and has been reading/following all the additional information BLANCH has summited to OIG since Fall 2015. This includes the "36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

~

Additionally, P Blanch called k.QJ(see Chron note) and reported that he was planning on sending Mr. BELL a letter d (i.e. letter was submitted in March 201~requesting an investigation into (b)

NRC's inadequate oversight at Indian Point. Thereafter, rn and Deputy AIG I had a phone C

conversation with BLANCH (see below for specifics of the call.) ~~j is waiting for this separate case to be opened and plans to support the named CA. (C)

OFFICIAL USE ONLY 4

OFFICIAL USE ONLY (7) Case 15 013, St. Lucie MSIV COBI Inspection. No new update . The following was reported in the last quarter summary, "St. Lucie MSIV failure after Component Design Basis Inspection (COB/). Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the COB/ inspection procedure _that the Case Agent can use as a guide during his investigation."

(8) Case 15-029, Pilgrim SRV CDBI Inspection. No new update . The following was reported in the last quarter summary, "Pilgrim SRV failure after a CDBI. Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation. "

(b)

(9) Case 16 013, NRC misuse of Funds. ~2) has supported CA j(b)(?)(C) jwith this investigation.EJassisted by: (1) contacted NRR technical advisor and received confirmation from the staff that both rules that were described in the FRNs have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the information gathered for this case. The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates . The CA is currently pursuing a copy of the contract.

(10) Case 16-012, NRC inappropriate process for digital control RIS. ~ has supported SA l (b)(?)(C) lwith this investigation. SA has submitted a CTF memo which Is pending. l(b)(?)(C) I assisted by ; (1) participated in the interview of the PM, (2) reviewed material for the 1/22/16 public meeting, (3) discussed this area during a meeting with Dave Lochbaum which is documented in a MTF, and (4) met wit~(b)(?)(C)  !(current OIG 112 rnd r l(?J(Cl rl(?)(C) ,. He explained the situation with ex-branch as it relates,...__

to_t_h-is_c_a_s_

e _. 1-n----

Magnum are several Chron Notes documenting Im !support activities.

(b)

(11) Case 16 016, Indian Point Tritium teak into Hudson River. ~~) is supporting CA~

with this case. On May 5, 2016, CA and lh Iinterviewed th,e (bl(7)(C) asked with inspecting the tritium leak. i~ ) lwill develop a MTF b;sed on information described during the interview .

Also, I'.~\ 1is In th~cprocessing of developing a working plan for this case based on SONGS (C

OFFICIAL USE ONLY 5

OFFICIAL USE ONLY lesson's learned.

~

On April 6, 2016, CA andE_j had a planning/update meeting on April 6, 2016 and discussed the following:

A. The allegation from, U.S. Senator Kirsten Gillibrand, requested OIG to:

While I know that the NRC has not yet completed Its investigation into the specific cause of the most recent leak, it has been brought to my attention that the leak most likely occurred during preparations for the next refueling outage, while waste stream water was moving to the waste storage tank. More troubling are reports that Entergy personnel were aware of related equipment problems as early as 2014, but failed to adequately repair or replace the equipment ...... Additionally, I would like information on whether the NRC's resident inspectors at Indian Point we aware of the malfunctioning equipment which caused the most recent leak, and whether It was nagged as a potential issue at any point prior to the discovery of the leak, and why the decision was made not to repair It In 2014.

B. CA an~ , !reviewed Indian Point (IP) prior inspection reports and learned that one of the 201 inspection reports referenced the sump pump being questioned in the allegation. Therefore , In NRC Inspection Report dated March 13, 2011 , OIG learned from the report that, (page 10): the NRC noted that "sump pumps required for mitigation of internal and external flooding were verified by licensee to be satisfactory. Also it stated, "the inspectors reviewed a sample of flood protection equipment testing and maintenance. Documents reviewed by the inspectors are listed in the Supplemental Information Attachment to this report .In Supplemental Information, A-3, Condition Reports, the NRC referenced : CR-IP2-201 1-1717, 28 Sump Pump in Fuel Storage Building (FSB)Testing Issues, 4/10/11.

C. On March 4, 2016, l(b)(?)(C) l e-mailed to CA that "the name of the sump pump at IP2, thereby contributing to the tritium leak from the reverse osmosis unit is "FSB Sump Pump 28."

D. The inspectors that performed the March 13, 201 1 dated inspection were: l(b)(?)(C) !(SRI) and l(b)(?)(C) I(RI). l<b)(?)(Cl jis currently (b)(?)(C)

(b)(7)(C) nd l(b)(?)(C) Iis currently a l{b)(?)(C) pn NR OFFICIAL USE ONLY 6

OFFICIAL USE ONLY sent to assist with the February 2016 inspection was l(b)(?)(C) ffl:'('l'ffl:4, - - - - - - - - . - ,

___,from Division of Reactor Safety .

F. Reviewed Fukushima Lessons Learned website for IP and found no noted concerns with sump pumps.

Next Steps:

1. lnterviewl(b)(7)(C) r~)I I-for background information ~2 to generate questions for CA to ask)

2. lnterivew j(b)(?)(C) I-the inspector who assisted with sI e inspection in March 2016

3. Request NRG e-mails for l(b)(7)(C) IDRB), l(b)(?)(C) I. and ....,l(b.....)(.....

7)""""

(C.,...

)--

(inspector).

4. Plant visit to review Corrective Actions.5. Based on items 1-4 above, lnterview:!(b)(7)(C) 1m(C IDRB), l(b)(7)(C) ~ and !(b)(7)(C)  !(inspector)

On April 7, 2016, CA and 11~l1interviewed l (b)(? )(C) I A MTF of the interview is in the case file. (C required for review per IP 71111 .01.

piI

~ d ded Inspection Procedure (IP) 71111.01 "Adverse Weather Protection" and the March 2011 Inspection Report to the case file (C

identified that "corrective action records" are (12) Case 16 014, Fukushima FOIA,ll.6Jsupported~ CAl(b)(?)(C) I by setting up and participating in a meeting with the alleger, Dave LOCHBAUM. Based on the discussion, LOCHBAUM might withdraw his allegation. 1~ 1prepared a MTF with details and analysis from the meeting. 2 (b)(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 7

OFFICIAL USE ON!=¥ (14) Case 16 032 , Currently working with CA on this case.

(

= ----.......,;...:;..-e=r;:.io

.:=--=

d...._t=h""'-1 e ~2 reviewed the followin ned to her:

(b)(7)(A),(b )(7)(C)

OFFICIAL USE ONILY 8

OFFICIAL USE ONLY (b)(7)(A),(b)(7)(C)

(3) Allegation 15-07582 - UFSAR Public Availability in ADAMS. lmldiscussed this allegation with alleger, David LOCHBAUM. The NRC reversed a SE~based on LOCHBAUM's request. To date~~2i I,s still working with LOCHBAUM to see if his concern with UFSARs has been resolved. For example, DC was just added to ADAMS in March 2016k which is approximately 1 year since it was docketed in Still monitoring delays in making FSAR publically available.

(4) Allegation 14 07379 - Chrystal River Seismic Concerns. Still working on Closure OFFICIAL USE ONLY 9

OFFICIAL USE ONLY Memo. No new update. Has been delayed due to priorities. Will try to get to Joe by Nov 10"'

COB. Region ll's Allegation Review Board's review of seismic concerns with Chrystal River -

The alleger believes the numerous engineering concerns he proved to Region ti were not adequately addressed. l(b)(?)(C) !reviewed the information provided by the alleger and identified a potential gap in the review process by the engineer who was tasked with assisting with this 6

allegation.jt l(?)(C) Imet with engineer to understand the process the engineer followed . LJ is still in the process of developed a closure MTF for this allegation.

(b )(?)(A),(b )(?)(C) b)

)

(7) Allegation 16 07859 - reviewed the information in Magnu~. (~) believes the NRC has

~

allowed Licensees to modify the plant with license conditions that are knowingly inadequate to O FFICIAL USE ONLY 10

OFFICIAL USE ONLY (b) meet NRG guidance. CA has not approached (7) for support (C)

(b)(?)(A),(b)(?)(C)

(9) Allegation 16 07800 - To date, this allegation has not been coorelated to this project although the initial review comments states that it should.

Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 Region IV counterpart meeting. See Chron note for further details. appears NRC reviewed in ROP inspection this component that ultimately failed. MTF will be drafted if research indicates NRC had a potential lapse in oversighlpl lwil follow-up on this allegation next quarter. (C)

(b)(4 ), (b )(?)(A), (b)(?)(C), (b)(7)(0)

OFFICIAL USE ONLY 11

OFFICIAL USE ONLY (b )(7)(A),(b)(7)(C)

(b)(4), (b)(7)(A), (b)(7)(C), (b)(7)(0 )

OFFICIAL USE ONLY 12

OFFICIAL USE ONLY (b)(4), (b)(7)(A) , (b)(7)(C), (b)(7)(D)

(b

=~::a...::..:.:.:...:.:.:.-=:.....c..:==J.1'fc>l communicated with the followin Stakeholder Grou s:

(1) Dave Lochbaum - spoke with LOCH BAUM several times during this quarter.

OFFICIAL USE ONLY 13

OFFICIAL USE ONLY LOCHBAUM blind copies~ on many communications between UGS and NRG.

(2) Region II Staff - Attended the Region II Counterpart Meeting in June. Also spent 1 day at Watts Bar and met with a Senior lnspectorl(bl(7J(C) !learned about Watts Bar 2 criticality and start~u as well as overall concerns by Region II inspectors regarding inspection findings. i~ shared information with OIG Management and several potential cases are being deve oped.

b)

Durin

• eriod (7) su orted OIG efforts to:

(C)

(1). DOE OIGl(b)(?)(C) Iprepared a presentation for DOE .... _ )_ _ _ _......I* The l(b_)(_?_)(C presentation focused on NRC's miss'ion with "DOE/NRC common connections" identified throughout the presentation. The link to the presentation is listed below.

(b)(4), (b)(?)(C), (b)(?)(D)

(b )(7)(A),(b)(7)(C)

(3) Training for Special Agents request on April 11, 2016  !~?)

f ~J resented the DOE/NRG power point tof >(7)<

0 arr ci d ADAMS training presented during the May All Hands CI Iper Tl's Meeting.Im !continues to work with T eam Leaders for technical training per the plan.

(4) Interface with OIG Audits

• as briefed by j(b)(?)(C) !regarding the 50.59 audit OIG is conducting.lfc~, lsugges that Audits review all the Special Inspections pe rformed in the last few years and determine if the equipment that failed was (1) previously inspected OFFICIAL USE ONLY 14

OFFICIAL USE ONLY

~

by NRC and/or (2) recently modified under 50.59. Also, l!cijsuggested Audits review the last 3 years of LERs and determine the same. Hence, did the equipmm at failed was (1 )

b) previously inspected by NRC and/or (2) recently modified under 50.59. (7) also provided information regarding "additional guidance" industry utilizes . Meaning, NEI 96 07 is not the only guidance used by Licensees .,~W7J !agree to obtain the name of the additional guidance.

Overall, it appears this audit is leading to many lose ends that appear to impact the effectiveness of NRC oversight of 50.59. Also, 50.59 audits might be eliminated per Project AIM.

(5) Interface with OIG Audits - Materials Teams I] )

met with the Material's team to items related to NRC's oversight of material exports. FcFJshared past and current investigation/allegations regarding this subject. The iu"ffit team will be reaching out to~once the team has determined the scope of the audit.

~

(6) Obtained the presentation material discussed in the April 11 , 2016 NEA newsletter regarding, "NEA Seminar on Lessons Learnt from the Waste Isolation Pilot Plant (WIPP)." Currently,IW,lis planning to discuss with AIGI the next steps.

ru The seminar summary states:

Recognizing the importance of safety culture and the impact of managerial and human factors on safety performance in the management of radioactive waste, the NEA held a seminar on 31 March 2016 to examine the lessons learnt from the accidents that occurred at the Waste Isolation Pilot Plant (WIPP) in 2014. Located in southeast New Mexico, the WIPP is the only deep geological repository for permanent disposal of transuranic waste in the United States. In February 2014, two isolated events - a fire and a radiological release- took place at the WIPP, triggering a rigorous accident investigation process. The NEA seminar reviewed the danger of complacency in the workplace and discussed means to create a safety-focused organization. The meeting discussions also revealed the effectiveness of social media as a communication tool. Participants underlined that emergency communications need to be open and transparent with the public in order to be effective and efficient. 11 (7) Interface with OIG Audits -W met with the Security team to discuss their upcoming

~

O FFICIAL USE ONLY 15

OFFICIAL USE ONLY audit on "NRC Foreign Exchange Engineers."~ shared past and current investigation/allegations regarding this subje~he audit team will be reaching out I

tolm once the team has determined the scope of the audit.

(8)1~, rrranged and attended meeting withl(b)(?)(C) Iregarding OIG Project for Economic Espionage. !(b)(?)(C) Idiscussed several new technology areas including "small modular reactors."

Innovative Activities (b)

(1 ~6)) working on a global summary of AIGl's use to brief NRC Offices.

Planned Investigative Activities :

Planned Investigative Activities :

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytics Interviews Conducted During Reporting Period :

06/15/2016 Paul Blanch 05/26/2016 ,: ( (

05/04/2016 04/07/2016 04/07/2016 Memos to FIie Prepared During Reporting Period :

06/30/2016 Case 14 012 06/13/2016 Case 16 032 IMC 1245 06/07/2016l(b)(7)(C)  !

06/07/2016 Case 16 032 05/27/2016 Case 16 032 05/12/2016 A16 07902 04/05/201 61......_______

04/19/201 ~ (b)(7)(C)

Other Documents:

OFFICIAL USE ONLY 16

OFFICIAL USE ONLY Additional Information:

Reviewer Comments:

Request Review:

I(b)(7)(E) Read Authorization: (Monitor), [All]

Level 1 Approval:

Level 2 Approval. Approved Joseph A. McMillan 07/08/2016 02:33.51 PM OFFICIAL USE ONLY 17

OFFICIAL USE ONLY Case Summary Report Prepared by: !{b)(7)(C) I 03/3//2016 Case Number & C 13 027 Special Subject OIG special project: Self Title Project: NRC Initiated Regulatory Oversight Date Opened 04/01/2013 Due Date 09/30/2016 Team AIGI Case Agent  !(b)(7)(C) tNRC Report for Period 03/31/2016 Report Type" Initial Ending*

Origination Dodink: ~

Allegation Facts:

t I

Sniplmage (017).JPG Investigative Plan:

Interviews:

(b )(7)(C)

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY

• (b )(7)(C)

Case Update: (b)

Durin this eriod the (7) cases:

(C (1) Case 16 001; NRO Pre-decisional Release of lnformationuillassisted the CA I )(?)(C) Iwho is assigned to this case. Although it is not categorized as a technical case, the (b

underlying investigation is based on technical documents produced by NRO engineers. For this investigation, thefil assisted with the following actions: (1 ) dld ADAM searches for the ru document properties (3 Mls), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the MLs (i.e. ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined "who" actually submitted the document in ADAMS (i.e.l(b)(?)(C) I),

(5) discussed "why" BCs would leave individual names in the document that was publicly released, and (6) research the policy/proce9ures for the "Open Door Policy" when meeting with a Commissioner.

(b)(?)(A),(b)(7)(C)

OFFICIAL USE ONLY 2

OFFICIAL USE ONLY (b)(?)(A),(b)(?)(C)

OFFICIAL USE ONLY 3

OFFICIAL USE ONLY Team OIG will be meeting with AUSA at the end of April 2016. TA is currently working on the technical presentation for the AUSA.

(b)(7)(A), (b)(7)(G)

(5) Case 13-042, Fort Calhoun Proactive Initiative. Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically, 0/G should attempt to determine why the NRC in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

litiiiITT ~

(6) Case 15-028, Indian Point. OIG management team , C A ~. and~metto discuss the status of this case. CA reported that he is addressing 2 specific issues (i.e. the tank contents and 2.206 process and lack of a formal letter) and has been reading/following all the additional information BLANCH has summited to OIG since Fall 2015. This includes the "36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

(b)

Additionally, P Blanch called 12) (see Chron note) and reported that he was planning on sending Mr. BELL a letter d (i.e. letter was submitted in March 2016) requesting an investigation into NRC's inadequate oversight at Indian Point. Thereafter, li2J and Deputy AIGI had a phone conversation with BLANCH (see below for specifics of theccall.) mis waiting for this separate (C) case to be opened and plans to support the named CA.

OFFICIAL USE ONLY 4

OFFICIAL USE ONLY (7) Case 15 013, St. Lucie MSIV CDBI Inspection. No new update . The following was reported in the last quarter summary, "St. Lucie MSIV failure after Component Design Basis Inspection (COB/). Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation."

(8) Case 15-029, Pilgrim SRV CDBI Inspection. No new update . The following was reported in the last quarter summary, "Pilgrim SRV failure after a CDBI. Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation."

(9) Case 16 013, NRC misuse of Funds. ~ has supported CA l(b)( )(C) 7 Iwith this investigation.l~~al assisted by: (1) contacted NRR technical advisor and received confirmation (C) from the staff both rules that were described in the FRNs have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the information gathered for this case. The FRNs appear to be geared towards changes. in the international market. This case includes misuse of funds related to radiation exposure rates. The CA is currently pursuing a copy of the contract.

(10) Case 16-012, NRC inappropriate process for digital control RIS . ~ has supported SA l(b)(?}(C} Iwith this investigation. SA has submitted a CTF memo which Is pending. ~

assisted by; (1) participated in the interview of the PM, (2) reviewed material for the 1/22/16 public meeting, (3) discussed this area during a meeting with Dave Lochbaum which is documented in a MTF, and (4) met withl(b)(?)(C) I(current (b)(?)(C) nd ...

r _)(?- )(-C)_ _ _ _ __,

!(b)(?)(C) I. He explained the situation with ex-branch as it relates to this case . In Magnum are several Chron Notes documentingll~ll support activities.

C (11) Case 16 0~lndian Point Tritium Leak into Hudson River.

(b) i2 is supporting CA (b){?)(C)

~b) with this case. (7) and CA met with Deputy and Team Leader to discuss ing this case and

~) ~

it was decided o open this case as a preliminary investigation . So far, the (7) and SA are (C) pursuing the name of the component that failed. , .not just "sump pump." as all information OFFICIAL USE ONLY 5

OFFICIAL USE ONLY (b) gathered to date in the case file . i2) believes this will become a full investigation based on the information reviewed to date. ~bl (12) Case 16 014, Fukushima FOIA, l(b)(7)(C) I supported CA .__ ____.by setting up and participating in a meeting with the alleger, Dave LOCHBAUM. Based on the discussion,

{b)

LOCHBAUM might withdraw his allegation. (7) prepared a MTF with details and analysis from (C) the meeting.

(b)(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 6

OFFICIAL USE ONLY (b )(?)(A),(b )(?)(C)

(3) Allegation 15-07582 - UFSAR Public Availability in ADAMSJ~l jdiscussed this (C) allegation with alleger, David LOmAUM. The NRC reversed a S CT based on

( )

LOCHBAUM's request. To date, \2) is still working with LOCHBAUM to see if his conce rn with UFSARs has been resolved . For example, DC was just added to ADAMS in March 2016k which is approximately 1 year since it was docketed in Still monitoring delays in making FSAR publically available.

(4) Allegation 14 07379 - Chrystal River Seismic Concerns. Still working on Closure 1

Memo. No new update. Has been delayed due to priorities. Will try to get to Joe by Nov 10 ~

COB. Region ll's Allegation Review Board's review of seismic concerns with Chrystal River-The alleger believes the numerous engineering concerns he proved to Region II were not adequately addressed. OIG fITTlreviewed the information provided by the alleger and identified EJ OFFICIAL USE ONLY 7

OFFICIAL USE ONLY a potential gap in the review process by the engineer who was tasked with assisting with..,,.,.,= this .,....---,

'b)(7)(G) (b)(7)(G) allegation. ' met with engineer to understand the process the engineer followed . .__ __ _.

is still in the process of developed a closure MTF for this allegation .

(5) Allegation A15 07758 -This allegation was turned into Case 16-013.

Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 ~egion IV counterpart meeting. See Chron note for further details. appears NRC reviewed in ROP inspection this component that ultimately failed . MTF will be drafted if research indicates NRC had a potential lapse in oversight ,~?) ill

. II . (G) follow-up on this a egatIon next quarter.

(b)( 4), (b)(?)(A), (b)(7)(C), (b)(7)(0 )

OFFICIAL USE ONLY 8

OFFICIAL USE ONLY l'b)(7)(A)

(b)(4), (b)(?)(A), (b)(?)(C), (b)(?)(ID)

OFFICIAL USE ONLY 9

OFFICIAL USE ONLY (b )(4), (b )(7)(A), (b)(7)(C), (b )(7)(0)

'f5T DurinQ this review oeriod (7) communicated with the followina Stakeholder Grouos:

s..s (1) Dave Lochbaum - On January 20, 2016, Dave Lochbaum was at NRC HQs and met with 7

01 [~\ nd SA (b)( )(C) . The following items were discussed:

(C'

• ancer Study - Industry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (I.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk. All in all, the results did not have any statistical outliers they were deemed significant but the study did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aware of any "international" or "regulatory changes" related to this study as described in Case 16-013.

• The Special Interest Group guru for radiation dose is._l(b-)(7_H_cJ_ _ __.I Dave will e-mail his contact information.

• Dave is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRG would require "evaluations" - not simple function testing - in order to demonstrate that equipment past its service life is still safe. The industry does not want evaluations to be OFFICIAL USE ONLY 10

OFFICIAL USE ONLY used as a control point.

• Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

(2) Paul BLANCH - on March 17, 2016~and Deputy AIGI Had a phone conversation with Paul Blanch regarding the letter BLANC~ te to Mr. Bell in March 2016. He alleged NRC's oversight was not appropriate. ~notes from the meeting include:

A. BLANCH's top 3 issues: [1] Violation of MD 8.5 and 8.11 (2.206 Petition), [2] IP operating in an unanalyzed condition, and [3] from Blanch's letter... item #5. Buried portion has never been analyzed. But does it need to be? OIG to check. NRC said (Art Burritt) told him, "the above ground portion has been analyzed." Per Burritt, in 2008, it wasn't analyzed ... however, there was an allegation in 2008 about the gas line near the river... 800 feet away.. in response to that allegation .... NRC responded a rupture won't jepordize the safety structures. But...they didn't seem to analyze the buried portion (in 2010 Paul did a petition) told him they just analyzed the above ground portion.

B. Paul said, "We can conclude the NRG has not done an adequate risk assessment....operating in an unanalyzed condition. We can't direct the AGENCY but we could send to the EDO and Commission and hopefully they will take action.

(3). Dave Lochbaum - On March 10, 2016,~et with LOCH BAUM. At the meeting, LOCHBAUM shared the following Inform~~;

• He met with the FOIA office regarding his concern with Fukushima FOIA requests. A separate MTF has been developed regarding this topic.

• He discussed his cu rrent project which is researching , reviewing, and understanding why NRC has a large number of RAls. He believes industry is putting pressure on NRG to reduce RAls. However, LOCHBAUM is looking into10 CFR 50.9 to see if Licensees are really the ones who need to be accountable for providing complete and accurate information.

• He is waiting for NRC to put all UFSARs back in ADAMS per SECY.

(b)

(7)

During this period, (C) supported OIG efforts to:

(1). DOE OIG. l(b)(?)(C) !prepared a presentation for DOE ... l(b_)_ _ )_ _ _ __,I The (7_)(C OFFICIAL USE ONLY 11

OFFICIAL USE ONLY presentation focused on NRC's mission with "DOE/NRC common connections" identified throughout the presentation. The link to the presentation is listed below.

(b)(4), (b)(?)(C), (b)(?)(D)

(b)(?)(A),(b)(7)(C)

(4) Training for Special Agents - Part 2 of Reactor Concepts Training was completed on February 4, 2016. All the traiining material is included in a chron note within 13 027.

Prepared an update to the SA Technical Training Plan and presented during February O IG Strategic Planning Meeting.

Second and third quarter training includes S-201, Materials Controls, Security Systems and (b)

Principles course (taught by TTC Staff) and ADAMS training (in ilearn). (7) is working With (C)

Team Leaders to get folks registered and completion of these courses .

(5). Attended Significant Determination Process (SOP) training at TTC. The goal is to teach this material to OIG Investigative Staff at the next All Hands Mtg .

Planned lrwestlgaWe Activities :

Planned Investigative Activities :

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

OFFICIAL USE ONLY 12

OFFICIAL USE ONLY (3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from projeot.

(4) Continue to support the initiative to improve data mining and analytics Interviews Conducted During Reporting Period :

12/10/201 ~ (o)(l)(C) I Memos to Fae Prepared During Reporting Period :

(b)(7)(A) "Unusual Event" LOCHBAUM LOCHBAUM Other Documents:

~

NRC_DOE_March 15 2016.pptx ADAMS #1 _Feb 8 2016_Copy ofOIG Questionable Access - Sensitive- Internal-No Review Required.xis Case (b)(?)(A)

Additional Information:

Innovative Activities (b)

( 1). (7) eveloped a "Summary of Notes" for each Oconee interview that was used for C

deve oping the NRC e-mail requests, interview question development and a "time line" of decisions NRC has made This 16 page document is attached to a Chron Note.

Reviewer Comments:

Request Review:

l(b)(7)(E) Read Authorization: [Monitor], [Alij Level I Approv.al:

OFFICIAL USE ONLY 13

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A),(b)(7)( C)

OFFICIAL USE ONLY Case Sunt,;;;.;-_; Report Prepared by:l(b)(?)(C) I 121.10120/5 Case Number & C 13 027 Special Subject OIG special project: Self Title Project; NRC Initiated Regulatory Oversight Date Opened 04/01/2013 Due Date 09/30/2015 Team AIGI Case Agent l(b)(?)(C) fNRC Report for Period 12/30/2015 Report Type* Initial Ending*

Origination Doclink : ;Jcase Update:

b Durin this eriod the (7) rovide su ort to the s ecial a ent for the followin cases:

~ (C)

(1) Case 16 001 , li:{J and SA met to discuss case . Although not categorized as a technical case, the underlying investigation is based on technical do cuments produced by NRO engineers_ During this working meeting, we performed the following action: (1) did ADAM searches for the document properties (3 MLs), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the MLs (i.e. ML14106A344 and ML14097A146), reviewed wed the informatir in the case file, (4) determined "who" actually submitted the document in ADAMS (i.e. (b)(?)(C) j1 and (5) discussed potential "next" investigative steps.

As a result of this meeting, the has the following action items:

1. Develop a MTF for the "Op or Policy" as it relates to the disposition of material prior to a meeting with the Commission. Completed

2. Develop a MTF for "Pre-Decisional Information" as it relates to the release of information for this case.

(2) Case 14~027, H/1 investigation. Completed the Draft ROI ; drafted questions for the Director of 01 intervi ew. Interview is scheduled for November 9, 2015J!Wiland TL plan to listen to the tape and add her testimony to the ROI by November 10, 201 s'."'Tn'e goal is to have the ROI ready for review/approval by COB 11/10/15. Completed the Draft Closed to File Memo for this case on 11/ 13/15. Awaitin review and approval by OIG management. Reviewed the comments from rnm-land (b)(?)(C) Marked the transcriP.t to 1denti where the answers were to questions. FinishecJthis on ues ay and discussed with (b)(7)(C) nd (b)(?)(C) was tasked with completing the H / 1 re port and providing to (b)(?)(C) 12/11/ 15.

(b)(?)(A),(b)(?)(C)

OFFICIAL USE ONLY 1

(b)(?)(A),(b)(7)( C)

OFFICIAL USE ONLY (2) Took the action to review all the actions/events related to the 480 Vac breaker fire and wrote a MTF, and (3) Assisted with the Closure Memo which recommended the following, which was based on the MTFs developed for this case: 0/G should consider initiating an investigation focused on the 480 Vac breaker fire and relating corrective action program problems. OIG should attempt to determine why the NRC in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports. In addition, Investigations should brief OIG Audits on its observation that 28 of the components identified as problematic through the FCS 0350 inspection process had received ROP oversight prior to the start of the 0350 inspection process, yet remained problematic. This information may be useful to Audits in connection with its FY 2016 Audit of NRC's Reactor Process. It is recommended that this proactive initiative be closed to the files of this office based on the above suggested courses of action.

(7) Case 15-028, Keeping abreast of the situation, however, no interactions with the CA.

Concerns with potential material in Indian Point tanks and inadequate allegation process .

I Supported the Case Agent by attending a meeting scheduled by the AIGI. Continue to take the initiative to be monitor the alleger's (Paul Blanch) concerns. [See discussion on Paul Blanch below.]

(7)

(8) Case 15 013, CA informed (C) that case is on hold due to priority case . St. Lucie MSIV failure after Component Design asis Inspection (CDBI). Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide ;during l his investigation.

(9) Case 15-029, CA informed hat case is on hold due to priority case. No help requested from CA. Pilgrim SRV failure a a CDBI. Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation.

(10) Case 15 041 , To support this case, developed MTF for regulations regarding NRG Resident Inspectors Requirements for complying with Licensee's internal policy. SA and TL interviewed Region IV staff on November 30, 2015. This case stemmed from Allegation A 15 07735.

(11) Case 16-012 (b)(7)(C) and SA (b)(?)(C) met with!{b)(7)(C) kcurre n t ~

and (bl(7HCl . e exp ained the situation with ex-bran~

relates to this case. (see ....,..... , ,um) [g;(7) nd SA developed questions and steps for the investigative plan. Also in (b a project are several relative documents for review.

)(C Durin this eriod the (7) reviewed the followin alle ation assi ned to her:

(C (1) All

• A15 0773 - Case 15 041 Failed NRC oversight at Brunswick Steam Electric Plant. (b)(7 )(C) reviewed the allegation that NRG used a camera instead of a physical walkdown of containment. A MTF was developed that identified the inspection procedure requirements for containment closure and potential conc(;)rns with resident inspector's availability to perform this aspect of an inspection. As a result, Case 15 041 was opened to investigate.

l (b )(7)(A),(b )(7)(C)

OFFICIAL USE ONLY 3

OFFICIAL USE ONLY (b )( 4), (b)(?)(A), (b)(?)(C), (b)(?)(D)

(b)(7l(A)

(4) Allegation 15-07582 - Delays in making FSAR publically available. This concern is being addressed within the merits of Case 15-007. Next step is to develop a close to file memo.

(5) Allegation 14 07379 - Closure Memo drafted. Will try to get to Joe by Nov 1o'" COB.

Region ll's Allegation Review Board's review of seismic concerns with Chrystal River - The alleger believes the numerous engineering concerns he proved to Region II were not adequately addressed. l(bJ(?)(C) !reviewed the information provided by the alleger and identified a potential a in the review process by the engineer who was tasked with assisting wit,,..,,_.,.~*.,.,,.,___,

allegation. bJ(7J(CJ met with engineer to understand the process the engineer followed . (b)(?J(CJ is still in thl5nl'l'l"l"r.~ of developed a closure MTF for this allegation .

(6) Allega~15 07758 - On 12/21/15, SAl(b)(?)(C) Iand ""' ,. ., 7)..,..,,

(b..)(= (C,..,....

) ---,discussed this allegation ~l > reviewed the 6 documents cited in the allegation. ngIneenng Intern (b)(?)(C) develope a a le that outlines the 6 documents and summarizes the subject of the ocuments.

The first 5 documents are related to "Radiation Protection" and the 6th document is related to "Power Plant Effluents." Each of these subjects h r d rule published in the Federal Register Notice in 2014 and 2015, respectively. (b)(?)(C) is currently researching the status of these rules. (b)(?)(C) has reached ou (b)(?)(C) ~(b)(?)(C) r or the EDO) for a status of the 2 citations 1.e. FR43284 and B0F Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 Region IV counterpart meeting. See Chron note for further details. appears NRC reviewed in ROP inspecti,on this component that ultimately OFFICIAL USE ONLY 4

OFFICIAL USE ONLY failed . MTF will be drafted if research indicates NRC had a potential lapse in oversight.

(b)(4), (b)(7)(A), (b )(7)(C), (b)(7)(0)

(b )(4), (b)(?)(A), (b)(7)(C), (b)(7)(D)

OFFICIAL USE ONLY 5

OFFICIAL USE ONLY examples.

Durin this review erlod m (C

communicated with the followin Stakeholder Grou s:

1 Dave Lochbaum - On Nov 19, 2015, Dave Lochbaum was at HQs for public meetings.

l l( l arnd Dave met and discussed:

. oc aum's concern with Green Piece's securit FOIA. He believes NRC has sent mixed messages and is working with l<bl(7 J(CJ !and (bJ(7 J( l to fix.

2. Lochbaum attended a Project AIM briefing. He ha no comment.

3. Lochbaum was surprised the Commission voted against the "Cummulative Effect of Regulation" that Licensees/Industry proposed.

4. Lochbaum discussed a concern - that he and other special interest groups are currently researchin - is the NRC cancelling phase II of the NAS cancer study. He mentioned that (b (7)( l is considering submitting a 2.206. The NRC is saying the project was cancelled due to funding but Lochbaum and other special interest grou s are wondering if it was cancelled due to "bad news." Lochbaum agreed to inform (b)(7J(C) once more information is available.

5. Lochbaum discussed a study he conducted 0~~1.1.LV,.*s reactors in the "merchant market" e the "regulated market." He will send analysis to (bl(7 l(C)

On December 1, 201 sJbH7J(CJ !reviewed his study (item 5 and determined, "that "utility owned" had 3 occurrences for quarters in column 3, 4 or 5, versus "wholesale commodity owned" had

38. Even though the number of ownerships was 5 versus 7, it's still a pretty big discrepancy."

Durin this erlod (CJ u orted OIG efforts to:

(2) Data Mining/ Electronic Data Mining and Analytics - Awaiting to assist Team Leader and Agents with "other" options once trials begin.

(3) Training for Special Agents - Completed Part of Reactor Concepts Training. All the training material is included in a chron note within 13 027. Although a scenario was developed for the training - which was based on an old allegation and included a developed template for technical case - there was not enough time to have SAs do. It was determined to incorporate the scenario in part 2 of the Reactor Concepts training class to be scheduled next quarter.

OFFICIAL USE ONLY 6

OFFICIAL USE ONLY Additionally, w orking on 2016 training plan. Met with AIG I and plan to have an updated Ian by November 12, 2015. Planning site visit to TTC to obtain training material for classes the (b)

~M~~~~~- ~

(4)1(b)(7)(C) ~requested review of letter to Chairman regarding Indian Point.

Ttie results to date .... t e Al - Jazeera website, so far, hasn't posted any of the information referenced in the letter Other Documents:

(b)(4), (b)(7)(A), (b)(7)(C), (b)(7)

(D)

A15 07758 Document Review Dec 2015.docx il,'7 - -

m~.1 I

Reacto r Concepts Tralnlng_Dec 2015 - jcp.pptx SONGS lessons learned Check-Off Sheet.docx

~

Reactor Concepts Training_License Renewal_Dec 201 5 - jcp.pptx E:lll'--

J-OIG_Raactor Training_Notes for Fukushima_Dec 2015.pdf Ela"-

)...

OIG_Reactor Training_Scenario ff1_Dec 201 5.pdf Allegation Facts:

see above Investigative Plan :

See below Case Update:

see above Planned Investigative Activities :

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytics Interview 10/07/201 Memos to FIie Prepared During Reporting Period :

12/01/2015 Proactive Initiative - Callaway 11/18/2015 Cas.",,-1.~i;..u.~9 Doc 10/16/2015MOI (b)(?)(C) Sep2015 OFFICIAL USE ONLY 7

OFFICIAL USE ONLY (b)(4), (b)(7)(A), (b)(7)(C), (b)(7)( D)

Request Review:

l(b)(?)(E) Read Authorization: [Monitor], [AIO level 1 Approval:

Level 2 Approval: Approved Joseph A. McM1ll.:in 01/1:1/2016 07:06:45 AM OFFICIAL USE ONLY 8

OFFICIAL USE ONLY Case Summa Report Prepwed by: (b )(7)(C) /0/ 14/2015 Case Number & C 13 027 Special Subject OIG special project: Self Title Project NRC Initiated Regulatory Oversight Date Opened 0410112013 Due Date  : 0913012015 Team AIGI Case Agent l(b)(?)(C) tNRC Report for Period 09130/2015 Report Type* Initial Ending*

Origination Docllnk: )

Allegation Facts:

Case 13-042: Based on the information identified in this proactive initiative, the following is a summary of supportive developments:

• 30 Chran Notes,

• 16 MTFs,

• 7 interviews,

• 9 cases supported,

• 5 allegations supported,

• 2 special interest group discussions.

• 3 technical classes taught,

• 2 technical presentations,

• and routine activities to support dally Interactions of OIG.

Case Update: (b)

During this period , th ~6\provide support to the special agent for the following cases :

(1) Case 14-027, Hll j'nyest;gation Coq1pleted the Draft Report which was reviewed by the AIGI. Next

---

~

step is to interview ofl(6)(7)(C)

( 2) Case 15-007, Fire Protection documents inappropriately withheld. Continued to support the Case Agent by: (1) provided additional information sessions with the Case Agent, (2) spoke with Dave Lochbaum about his concern now that NRC reversed the SECY, and (3) arranged a meeting at Headquarters (week of Sept 8th) for Case Agent to meet with Dave Lochbaum. Lochbaum communicaled at the OIG meeting lhat he was satisfied with the NRC SECY reversal and was withdrawing his concern with OIG. On September 22, 2015, the Union of Concerned Scientist. published on their website the following: The Commission voted unanimously in June 2015 to approve the NRC staffs request to restore public access to fire protection and emergency planning documents submitted to it by nuclear pla nt owners, Additionally, "UCS is even more appreciati ve ofthe NRC reassessing its document w1i hholding policies holistically and revising them globally. As a result, not only w/11 the public regain access to fire protection and emergency planning documents, but also to approp riate documents 0

spanning the NRC's wide range of respons1bt1ities.

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY (3) Case 15 013, St. Lucie MSIV failure after Component Design Basis lnspection(CDBI). Provided the Case Agent with 2 MTFs that Identify the areas NRC provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation.

(b)(7)(A),(b)(7)(C)

(7) Case 13-042, Fort Calhoun Proactive Initiative. Continued to supporting this case by: (1) Took the action to do an extensive analysis of the issues found during the 0350 inspection and determine if NRC had reviewed any of these concerns in prior inspections and prepared a MTF, (2) Took the action to review all the actions/events related to the 480 Vac breaker fire and wrote a MTF, and (3) Assisted with the Clo.sure Memo which recommended the following, which was based on the MTFs developed for this case: OIG should consider initiating an investigation focused on the 480 Vac breaker fire and relating corrective action program problems. OIG should attempt to determine why the NRC in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports. In addition, Investigations should brief OIG Audits on its observation that 28 ofthe components identified as problematic through the FCS 0350 inspection process had received ROP oversight prior to the start ofthe 0350 inspection process, yet remained problematic. This information may be useful to Audits in connection with its FY2016 Audit of NRC's Reactor Oversight Process. It Is recommended that this proactive initiative be closed to the Illes ofthis office based on the above suggested courses of action.

(8) Case 15-028, Concerns with potential material in Indian Point tanks and Inadequate allegation process. Supported the Case Agent by attending a meeting scheduled by the AIGI. Continue to take the initiative to be monitor the alleger's (Paul Blanch) concerns. (See discussion on Paul Blanch below.]

(9) Case 15-029, Pilgrim SRV failure after a CDBI. Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component. Additionally, provided a "check off Sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation. ~

During this period, the li:J reviewed the following allegation assigned to her :

( 1) Allegation A15 07735 - Failed NRC oversight at Brunswick Steam Electric Plant. (b)(l)(CJ reviewed OFFICIAL USE ONLY 2

OFFICIAL USE ONLY the allegation that NRC used a camera instead of a physical walkdown of containment. A MTF was developed that identified the inspection procedure requirements for containment closure and potential concerns with resident inspector's availability to perform this aspect of an inspection. As a result, Case 15 041 was opened to investigate.

(b )(7)(A),(b )(7)(C)

(b)(7)(A),(b)(7)(C)

(4) Allegation 15-07582 - Delays in making FSAR publically available. This concern is being addressed within the merits of Case 15-007. Next step is to develop a close to file memo.

(5) Allegation 14 07379 - Region ll's Allegation Review Board's review of seismic concerns with Chrystal River - The alleger beli~i!!il,,,,!,Mlii..li'umerous engineering concerns he proved to Region II were not adequately addressed. (b)(?)(C) eviewed the information provided by the alleger and identified a otential gap in the review process y t e engineer who was tasked with( lol~in, with this allegation (b)(7)(C) met with engineer to understand the process the engineer followed. (b * ( ) is still In the proces developed a closure MTF for this allegation.

~

During this review period l!illcommunicated with the following Stakeholder Groups :

(1) Paul Blanch - spoke with Paul numerous t1mes regarding his concerns with Indian Point. Paul has several concerns with the modified gas line approved by FERC. The revised gas line is 42 inches and Paul has concerns that the hazard analysis done and reviewed by the NRC is inadequate. Paul's 2.206 petition was unsubstantiated. Currently keeping abreast of the situation.

(2) Dave Lochbaum - spoke with LOCHBAUM regarding his September 2015 "Blog" on NRC's reversal of the SECY to with hold Fire Protection Information and other previously protected information (see details above.) Also spoke with Dave prior to his visit to the NRC regarding Paul Blanch's concern with Indian Point.

(b)

During this period , ~2) supported OIG efforts to:

(1) Contacted an EPRI representative regarding Information sharing. Next step is to meet to discuss details.

(b)(4), (b)(7)(A), (b )(7)(C), (b)(7)(0)

OFFICIAL USE ONLY 3

OFFICIAL USE ONLY (3) Data Mining

• Currently using the new ADAMS advanced search features . Also Implementing the new process to acquire "protectedn ADAMS information.

(4) Electronic Data Mining and Analytics - Awaiting to assist Team leader and Agents with "other" options once trials begin.

(5) AJlegation Management System - Used AMS for several cases and an allegation during this quarter as noted within this report. lo particular, one of the Diab lo Canyon allegations appear to be relevant to both l(b)(?)(C) leases.

(6) Training for Special Agents - Taught the Sharepoint Technical Training (Reactor Over sight Process) twice this quarter. Also assisted with Regulatory Process Training for the Agents who still needed the training.

Planned lm,estigative Activities :

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from p roject.

(4) Continue to support the initiative to improve data mining and analytics (b)(4), (b)(?)(A), (b)(?)(D)

Other Documents :

(b)(?)

DC (A)

~

Presentatln_September 2015.rev 1.pptx Additional Information:

• Developed a "check-off' sheet for Inspection Procedure 71 111.21 , "Component Design Basis Inspection," for the Case Agent to utilize in his investigations. Also filled out the "check-off sheet for Case 15 029 and Case 15 013 with information from NRC documents that identified what items were reviewed during the inspection and what items were found to be the root cause of lh!:l component failures.

• Developed and implemented a method to "catalog" relative information from review of information obtained from subpoena or un-r*edacted FOIAs. Curren tly using the "catalog" of information to assist with investigations.

OFFICIAL USE ONl Y 4

OFFICIAL USE ONLY Reviewer Comments:

Investlgatlve Plan:

Case Update:

Planned Investigative Activities :

Interviews Conducted During Reporting Period :

09/15/201 (b)(l)(C) 09/15/201 09/14/201 09/14/201 09/14/201 08/19/201 07/16/201 Memos to File Prepared During Reporting Period :

09/04/2015l(b)(l)(A) I 09/03/2015 Allegation 15 07735 08/24/2015 Case 15 013 IP and Inspection Report 08/21/2015 Case 13 042, Vac Breaker Analysis 08/21/2015 Case 13 042, ROP analysis 08/18/2015 Case 15 029, IP and Inspection Report 08/07/2015 Case (b)(7)(A), (b)(7)(C) 08/03/2015 MTF ~(b~(" ""'....,,,..(~bl:(7~ l'!J(A:.":'l";l(t,"'l:)(~l:'(C~

l!!) - . , -- - " " '

07/30/2015 MTF an (b)(7)(A) ummary of A4NR Testimony July 2015 07/30/2015 Case 15 0101 and (b)( A4NR testimony 07/24/2015 Case (b)(7)(A), (b 7 C 07/21/2015 Case 15 006 and (b )(7)(A) 07/17/2015 Case b 7 A b 07/13/2015 Case °:Mi"'~~ n~sp_.,e...,

ct=t"o--n~n~ a,-y""."'s1~s- - -....

07/13/2015 Case 15 029, Comparison of NRC inspection reports 07/12/2015 Case 15 013, Comparison of NRC inspection reports Other Documents:

Additional Information:

Reviewer Comments:

Request Review:

l(b)(7)(E) Read Authorization : [Monitor], (Alij OFFICIAL USE ONLY 5

OFFICIAL USE ONLY Level 1 Approval Level 2 Approv::il. Approved Joseph A. McMillan 01/1212016 07:07:14 AM OFFICIAL USE ONLY 6

OFFICIAL USE ONLY Case :Summary Report Prepared bJ~l(b )(?)(C) I 06/30/2015 Case Number & C 13 027 Special Subject OIG special project: Self Tide Project: NRC Initiated Regulatory Oversight Date Opened 04/01/2013 Due Date 09/30/2015 Team AIGI case Agent  !(b)(?)(C)

Report for Period 06/30/2015 Report Type* Pending Ending*

Origination Doclink: j Case Updam: l'.bll During this period, the ~~) provide support to the special agent for the following cases :

(1) Case 14-027, H/I investigation. Significantly supporting the ROI which has been briefed to the Team Leader. Preparing the final draft and referencing for review by Team Leader and Case Agent n

SL_ROI_Case 14-027_June 25 2015.docx (2) Case 15-007, Fire Protection documents inappropriately withheld. (1) have briefed the Case Agent and Team Leader several times on the status of the SRM developed by the Staff in regards to this case's concern, (2) working with OIG Attorney to determine the basis for the legal concerns identified in this case, (3) historical recap/time line for the promulgation of 10 CFR 2.390 rule, (4) historical recap/time line of MD 3.4, (5) FRN notices for withholding of Information and (6) staff's internal policy and procedures for fire protection information. Preparing a MTF to summarize this information and preparing a list of folks to interview and questions for the interview.

(3) Case 15 029, St. Lucie MSIV failure after Component Design Basis lnspection(CDBI). (1) Reviewed the Licensee's 50.59 Applicability Document and developed MTF, (2) Summary of Contact with NRR Project Manager for the Component Design Basis Inspection and developed MTF, (3) Found a document i n ADAMS developed by NRC Generic Communication's Branch that documents the root cause of the main steam isolation valve failure. Currently preparing a MTF, and (4) Reviewed the CBDI inspection procedure (IP71111.21) with the Case Agent and took an action to develop an working outline (similar to a check-off list) of this IP and ultimately fill out the outline for understanding ifhow there was the potential that N RC had reviewed information prior to the failure.

(4) Case 14-007, Pre-decisional information regarding Fukushima Task Force Hardened Vents decision.

Researched and reviewed documents related to this case. Developed a MTF that documents the Commissioner's decision which was chosen from several options provided by the Staff (ultimately, the staff recommended a different option as compared to the opinion selected by the Commission) and public documents (to include financial and special interest groups discussions) describing the overall situation with the Commission facing several options related to vents.

(5) Case 15-025, G:Drive access by RES contractor, Did a sampling review of the G:Drive obtained by OIG to support this case. Develloped a MTF with results.

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY (6) Allegation-15-0766, Region II findings for Summer Station. Prepared 2 MTFs to support the Case Agent for down-playing inspection findings at Summer Station.

(b )(7)(A),(b )(7)(C)

(9) Case 13-042, Fort Calhoun Proactive Initiative. Supporting this case by; (1) Prepared a MTF regarding the flood issue with Fort Calhoun. This MTF provided a historical review of events and regulatory actions related to it, (2) Participated in a case review briefing with OIG management. We discussed the overall objective of this case and agreed to perform several tasks, (3) Took the action to do an extensive analysis of the issues found during the 0350 inspection and determine if NRC had reviewed any of these concerns in prior inspections, and (4) Took the action to review all the actions/events related to the 480 Vac breaker fire.

(10) Case 15-028, Concerns with potential material in Indian Point tanks and inadequate allegation process . Supporting the Case Agent by (1) Reviewing the original UFSAR to determine if/what tanks are in the licensing basis and (2) the status of his allegation (open/pending/closed, etc.)

1

1:::::

(11) Case 15-029, Pilgrim SRV failure after a CDBI. Currently supporting Case agent by prepar1ng

i~:::::::,:-0::lgned to her :

{1) Allegation 15 07693 - OIG received an anonymous complaint describing failed NRC oversight by resident Inspectors for a safety Injection tank (SIT) pipe leak during the week of April 13, 2015. The alleger belmthe plant should have entered technical specification 3.0.3 that requires an accelerated shutdown. (b)( ) eview learned that the Licensee declared the SIT inoperable and Technical Specification Limiting C n of Operation (LCO) 3.5.1 action "b~ was entered which required the SIT to be restored to Operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or shut down to Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In accordance with TS and plant procedures, operators subsequently shut down the unit to repair the leak. This condition was determined to be within the plant capability to maintain SIT requirements.l(b)(?J(CJ ~ eveloped MTF recommended closure of this allegation.

(b )(7)(A ),(b )(7)(C)

OFFICIAL USE ONLY 2

OFFICIAL USE ONLY relevant RIAs and (3) Site Visit to review calculations based on results of analysis and determine if INPO has documented any concerns in this area.

(4) Allegation 15-07582 - Delays in making FSAR publically available. This concern is being addressed within the merits of Case 15-007. Spo~e with Dave LOCHBAUM and he has recieved the FSAR's that he requested during this quarter. Plan to continue monitoring as described In Case 15-007 above.

(5) Allegation 14 07379 - Region ll's Allegation Review Board's review of seismic concerns with Chrystal River - The alleger b e l ' ~ umerous engineering concerns he proved to Region II were not adequately addressed b ( ( ) reviewed the information provided by the alleger and identified a otential gap in the review process y e engineer who was tasked w i t h ~ with this allegation. ( l 7)(C) met with engineer to understand the process the engineer followed.~~~.Js in the process of eve opea a closure MTF for this allegation.

During this review period l1!l)Icommunk:ated with the following Stakeholder Groups :

(1) Paul Blanch - spoke with Caul numerous times regarding his concerns with Indian Point Paul submitted an allegation to OIG which is preliminary case 15-028 (i.e. described above.) Paul has several concerns with the modified gas line approved by FERC. The revised gas line is 42 inches and Paul has concerns that the hazard analysis done and reviewed by the NRC is inadequate. Since Paul submitted a 2.206 petition, OIG is monitoring the situation and keeping abreast of the situation.

(2) Friends of the Earth - spoke with senior Strategic AnalystJ(b)(?)(C) I regarding the presentations by NRC and PG&E at the April 28th public meeting to discuss PG&E's 50.54(f) seismic I

analysis results. Preparing~ document the discussion and l(b)(7)(C) concerns that he submitted in an e-mail to t h e ~

(3) Dave Lochbaum - spoke witlh LOCHBAUM regarding his January 2015 "Blog" on Turkey Point. He shared his opinion in an e-mail that will be included in the Turkey Point analysis. Also spoke with Dave regarding his concern with Fire Protection information and he has not been contacted by NRC to date regarding his request to redact the SECY (4) Alliance for Nuclear Responsibility - met with 2 members regarding Diablo Canyon. They share concerns and information regarding the seismic information presented in various public meetings. This information will be coi dered in both Oiablo Canyon cases.

During this period ' lli{I supported OIG efforts to :

(1) Developed Case 15-029 as a proactive initiative from review of NRC news . As part of Region l's triennial component design bases inspection (CDBI), Inspection Procedure (IP) 71111.21 at Pilgrim Nuclear Power Station in May-June 2014. NRC selected the SRV, RV-203A as a sample and reported no finding were Identified. Seven months later, in January 2015,, SRV 'A' was unavailable due to pilot valve leakage during a plant shutdown and its sister valve "C" failed ( Reference 5 p. A 1-1 ). OIG learned the four SRVs at Pilgrim were replaced in 2011 and subsequently had numerous issues. A special inspection team was dispatched on February 2, 2015 and issued eight findings, one of the findings was potential white for "the 'A' SRV was inoperable for greater than its Technical Specification allowed outage time."

Additionally, the NRC spokesman in the Manomet Current articl*e states, "NRC inspectors found that eh problem with the valve should have been found and fixed during a plant shutdown in February 2013, he wrote in an e-mail. Instead, the problem with those valves was found when they were inspected after the January 2015 shutdown."

OFFICIAL USE ONLY 3

OFFICIAL USE ONLY rb )(7)(A), (b)(7){C), (b )(7)(0 )

(3) Data Mining - Currently using the new ADAMS advanced search features .

(4) Electronic Data Mining and Analytics - Awaiting to assist Team Leader and Agents with "other" options once trials begin.

(5) AlJegation Management System - Used AMS for several cases and an aUe ation during this quarter as noted within this re ort. 1n particular, one of th (b)(?)(A) ppear to be relevant to both~ and (b)(?)(Cl ases.

(6) Training for Special Agents - Coordinated and attended "Resident Inspector Training."

Currently working' with TIC branch chief for instructors to teach Reactor Concepts during the 4th quarter of 2014.

Planned Investigative Activities :

(1) Continue supporting the Case Agents as described above, (2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytic;s:

(5) Review Diablo Canyon information provided by Friends of the Earth~(b)(?)(C) I- regarding the presentations by NRC and PG&E at the April 28th public meetin to discuss PG&E's 50.54(f) seismic analysis results. Prepare a MTF to document the discussion and (b)(?)(C) concerns that he submitted in an e-mail l o the ~

(6) Document LOCR'BmJM's e-mail regarding his synopsis of Turkey Point's ultimate heat sink

,_, .. *~"ire ric:P (b )(?)(A), (b)(?)(C), (b)(?)(D)

Interviews Conducted During Reporting Period

• Memos to FIie Prepared During Reporting Period :

06/19/2015 MTF_Case 15 029_Summary of Contact_lSOM 06/19/2015 Case 15-029_Review of 50.59 process document 06/16/2015 MTF_Case 25 010_ Review of Commission's ruling on FOE DC petition 06/12/2015 MTF A-15 07693 St. Lucie Tech Spec June 2015 06/02/2015 MTF]b)(?)(A),(b)(1)(C)  !

05/28/2015 MTF_Case 13 042_ Flood OFFICIAL USE ONLY 4

OFFICIAL USE ONLY 05/19/2015 MTC_Case 14-007_ Hardened vents 05/15/2015 MTF_ Case 15-025_G:Drive review for contract information 05/14/2015 MTF - For Allegation A-15-07666 - Summer ROP summary 05/14/2015 MTF - For Allegation A-15-07666, ROP Finding Responsibilites, IMC 0102 05/13/2015 MTF for summary of Non-Cited Violations and Findings 05/07/2015 MTF SON S Lessons Learned and OIG Event Inquiry 04/21/20 15.MTF (b}(7)(A) DC site review of documents 04/16/2015 MTF - . uc1e - s mmary of adverse actions 04/16/2015 Review of Formerlici.r,;1-.~;!:!:-;1.11.11.1~- - - - ,

04/14/2015 MTF_OIG Strat Plan (b)(7)(D) 04/08/2015 Case (b)(7 (A), (b)(7)(C}

Other Documents:

(b)(4), (b)(7)(D)

Additional Information:

Reviewed ~he SONGS Lessons Learned Document and developed a MTF describing the influences derived from the O IG Event Inquiry. The findings within the 0IG Event Inquiry report were addressed in 7 out of the 17 actions identified by the staff.

Reviewer Comments:

Request Review*

Read Aulhonzalion: [MonitorJ, [All]

(b )(7)(C)

Level 1 Approval: Approved 06/30/2015 05.14.14 PM Level 2 Approval: Approved Joseph A. McMillan 07/06/2015 08 21*37 AM OFFICIAL USE ONLY 5

OFFICIAL USE ONLY Case Summa Report 03/30/1015 Case Number & C 13 027 Special Subject OIG special project: Self Title Project: NRC Initiated Regulatory Oversight Date Opened 04/01/2013 Due Date 09/30/2015 Team AIGI Case Agent l(b)(7)(C) tNRC Report for Period 03/31/2015 Report Type* Pending Ending*

Origination Doclink: _,

Case Update: l(b)I During this period, the (7) provided support to the special agent for the following cases :

(C (1) Case 13-048 - Palisades pressure boundary leak - attended the 01 Briefing in February - reviewed Ol's ROI nublished in March and develoned a MTF with recommendations for the ""'""" aaent (b )(7)(A),(b)(7)(C)

(4) Case 14-027 - H/1 lnvesti ation - (a) Assisted with developing questions for 4th interview of Ol's Operations ~ e r (b)(7)(C) . (b) assisted with (b)(7)(C) interview. c. participated in agent's case briefing wlth~n [b)(7MC)

(5) Case 15-007 - NRC staff inappropriately withheld documents pursuant to FOIA rocess - met with alleger (LOCHBAUM) who had meetings with a Commissioner, the Chairman, and (b)(7)(C) to discuss his concern . LOCHBAUM provided OIG the result of meetings.nevelo*'p =-::'

e::i""::"a"l'T'l"l""':t'='

o _ ___.

document the current NRC position with this allegation. OIG will contin~ monitor.

REi During this period, the fcl reviewed the following allegations assigned to her :

(b)(7)(A)

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY (b)(7)(A),(b)(7)(C)

(2) All ation 15-07582 - Delays in making FSARs publically available - as discussed in Case 15-007 abov (b) . et with LOCHBAUM and MTF describes current status of NRC statf.!(b)(7)(C) !wlll continue to follow (?)(C (3) Allegation 15-07639 - NR *

• g and persisting in activities related to the Fukushima Near Term Task Force Recommendation (b)(?)(C) reviewed the allegation material and documented the results in a MTF. Since the Fukushima recommendations are currently in rule-making; the alleger's concerns are premature at this point in the process.

(4) Allegation 15-07601 - Con~ r d ing NRC staff failure to respond to ACE questions pertaining to Limerick Nuclear Power Plant. (b)( ( s currently following-up on an ACE concern regarding NRC discussions with state officials an pans to document analysis in a MTF by next quarter.

(b)

During this period, (7) communicated with the following Stakeholder Groups :

(C)

(1) Paul BLANCH - spoke with him several times regarding his concern with Indian Point and the gas line

~:~)(71~~~*a:=-*

retrofit project. He wrote a letter to the Chairman and submitted a 2.206 petition. Currently awaiting response from the NRC and reviewing the technical information sent to OIG by BLANCH.

met ~hFJE Sen;or Strateg;c Analyst, lib)(7)(C) met wit LOCHBAUM has no actions for OIG.

Irelated to cases Li~~~~~ twice to discuss multiple areas of concern. At this time, During this period .~upponed OIG efforts to :

(b)(4), (b)(7)(D)

(2) Social Media Software - LEXIS/NEXIS - assisting with trial of this software. Using Indian Point concern (BLANCH) as basis of trial.

(3) Electronic Data Mining and Analytics - assisting with trial of NRC software (Content Analytics) and E-discovery.

4 Alie ation Management System - (b)(7)(A)

(b){7)(A) . Currently Reviewing a....,.e_g_a-t1-o-n--,,,...

1-es___ r_o_m

- -re- .-

1m

_ m_ary

-- re_v_1_ew

- , - e-re- ar_e_

m v1 ua s w o might have information for bo (b)(?)(C) cases. (still working)

(5) Training for Special Agents - working on "Resident lnspector Training" with TTC instructors for week of April 20th at PDC.

Planned Investigative Activities :

Continue supporting the agents with their cases and projects. Continue providing daily technlca1 support to OIG staff. Continue.keeping abreast of all current technical areas as communicated by the NRC, Licensees, Special Interest Groups, and Industry Support Groups.

Based on requests from the AIGI and in accordance with the OIG Annual Plan, continue to: (1) analyze "Column 3 and 4" plants and identify proactive initiatives, (2) try to use social media software to Identify proactive initiatives, (3) data-mind allegation material to identify proactive initiatives, and (4) recommend disposition of allegations and proactive research based on analysis.

Interviews Conducted During Reponing Period :

I OFFICIAL USE ONLY 2

OFFICIAL USE ONLY Memos to File Prepared During Reporting Period :

03/26/2015 MTF - Summary of Contact for Congressional e-mails - DC 03/24/2015 Reyjew of Pa~'sades BPI - fo.r case 12.oss 031201201 sl..,.

(b_)(_?)_(A_)__,,..,,._,........,__,,._..--.,--..-=---.-----------'I

• 03/20/2015 Summary of ontact - Friends of Earth 03/20/2015 LEXIS/NEXIS Social Media Monitoring Trial .---------.

l(b 03/13/2015.,:a.1.LJw.mac.1.m.L..cw.aci.~;U,LQ,.LLIIL..,;,t:l,l"-',l,,L,Lllll......i....;.:;i.s:.Q 13-027 and )(?)(C) 02/20/2015 (b)(?)(A), (b)(?)(C)

• 01/12/2015 . uc1e Other Documents :

(b)(?)(A),(b )(?)(C)

AddlUonal Information :

1. Developed and participated in 2 interviews with stakeholders: (1) Dave LOCH BAUM for Case 15-007 and Allegation 15-07639 and 2 Frie..,n,..,.d.,.,s,...,o.,. f ,...

th_e______

Earth senior analyst (b)(?)(C) for (b)(?)(A) 2 . Assisted with 4 interview or b 7 c

3. Assisted with 1 interviews for..........

as..._e.....,........,,......,....

4. Attended technical training at the TTC during the weeks of January 25th and March 9th Reviewer Comments:

Request Review:

Read Authorization; [Monitor], [Alij Level 1 Approval:

Level 2 Approval. Approved Joseph A. McMillDII 04/0112015 05.01 :02 PM OFFICIAL USE ONLY 3

OFFICIAL USE ONLY Case Summary Report Prepared by: l(b)(7)(C) I Jl/]3/1014 Case Number & C 13 027 Special Subject OIG special project: Self Title Project: NRC Initiated Regulatory Oversight Date Opened 04/01/2013 Due Date 09/30/2015 Team AIGI Case Agent l(b)(7)(C) tNRC Report for Period 12/31/2014 Report Type* Initial Ending*

Origination Dociink: L~

Allegation Facts:

OIG special project to strengthen NRC's efforts to protect public health and safety and the environment by proactively monitoring agency technical and regulatory processes, nuclear industry trends, trade press, as well as other sources to identify potential problematic areas in NRC regulatory oversight of licensee.

This special project is a continuation of a previous project, OIG Project case number 10-12.

I nvestigative Plan:

1. The 01ol""" (b..,..)(=7,...,.

)(C.,. .),- - - - - - - - - - - . lwill monitor agency reports, ADAMS comrnunicahons, trade press and other sources to identify potential breakdowns in NRC regulatory oversight.

2. The~ wjil monitor the issues from one (1) and identify potential adverse trends in specific agency oversight programs. The (b)(?) will propose an allegation to the (b)(?)(C) and AIGI and receive concurrence from the (b)(?)(C) and ATGJ that the issue should be treated as an allegation.

3. The [~t will review assigned allegations and make recommendations.

(b )(7)

4. Based on the results of the review (from 2 or 3 above) th ill propose either closing the alle ation to file or opening a case for investigation to the bl( )( l nd AIGL As required, the (b)(7) ill assist OIG staff with technical analysis for investigations.

(C)

(b)(7)

5. The (C) ill conduct technical analysis for safety and securin, initiatives identified in the 010 Annual Plan. Based on the results of the analysis, the ~~t will follow the process steps listed above in 2 and 3. The includes the following:

• Allegations that NRC employees improperly disclosed allegers' identities and allegations, NRC employees improperly handled alleger concerns, and NRC failed to properly address retaliation issues involving licensee employee who raised health and safety concerns at nuclear plants.

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY

• Examine allegations that NRC has not maintained an appropriate "arms length" distance from licensees, particularly in the inspection process.

• Interact with public interest groups, individual allegers, and industry workers to identify indications of _lapses in NRC regulatory oversight that could create safety and security problems.

• Conduct a number of Event and Special Inquires into specific events that indicate an apparent shortcoming in NRC's regulatory oversight of the nuclear industry's safety and security pn;>grams to determine the appropriateness of the staffs actions to protect public health and safety. *

• Proactively review and become knowledgeable in areas ofNRC staff regulatory emphasis to identify emerging issues that may require future OIG involvement. Also provide real time OIG assessments or the appropriateness of NRC staffs handling of contentious regulatory activities related to nuclear safety and security matters.

Case Update: mb)

During this period, the (2 provided support to the special agent for the following cases:

(1) Case 13-048 - Pali s pressure boundary leak - clarified tech spec information and placed in a case file chron note (b)(7)(A),(b)(7)(C)

(3) Case 14-027 - H/1Investigation - a. reviewed the 0 1case file, researched NRC's regulations. policies and procedures, and provided an analysis for potential lapses in an H/1 investigation. Developed two MTFs which were placed In the case file. One of the MTFs included an analysis of "all available evidence and the other MTF included an analysis of the "adverse actions as described by the alleger. b.

Assisted with developing questions for witness Interviews. c. Assisted with 3 witness interviews.

(4) Case 13-052 - Inspection Findings at Lovelace - reviewed a11d analyzed the draft and final inspection reports provided by the alleger. Created a MTF that Identified the differences or "gaps" between the draft and final inspection reports. This MTF is in the case file.

(5) Proactive initiative for review of allegation - Region II - St. Lucie - spoke with alleger and he believes the NRC staff did an inadequate review of the Cl's allegation related to diesel generators. Requested and have received all the allegation material from the Region and am currently reviewing and awaiting Region II second close-out letter to the alleger because the alleger appeal to them that his concern wasn't addressed fn the Fall 2014 close-out letter. The Region is scheduled to complete the review of his appeal by the 2nd quarter of 2015.

(b)(?)(A)

(b)(?)(A),(b)(7)(C)

(b)(?)(A)

OFFICIAL USE ONLY 2

OFFICIAL USE ONLY Planned Investigative Activities :

Continue supporting the agents with their cases and projects. Continue providing daily technical support to OIG staff. Continue keeping abreast of all current technical areas as communicated by the NRC, Licensees, Special Interest Groups, and Industry Support Groups.

Based on requests from the AIGI and in accordance with the OIG Annual Plan, continue to: (1) analyze "Column 3 and 4" plants and identify proactive initiatives, (2) try to use social media software to identify 1

proactive initiatives, and (3) data-mind allegation material to identify proactive initiatives.

Interviews Conducted During Reporting Period :

Memos to FIie Prepared During Reporting Period :

12/23/2014 St. Lucie Main Steam Isolation Valve Event 12/19/2014 Dave LOCHBAUM teleconference summary and subsequent meeting minute notes with OIG management team and agents Other Documents; Additional Information:

l(b Assisted with 1 interview for )(?)(A)

Assisted with 3 interviews for Case 14-027 Reviewer Comments:

Request Review; r b)(7)(E)

Read Authorization: [Monitor], [All) l evel 1 Approv<1I:

level l Approval Appr,llled Joseph A. McMillan 12/2312014 06:02:46 PM OFFICIAL USE ONLY 3

OFFICIAL USE ONLY Case Summary Report PrepG*red by:!(b)(7)(C) ! 09/30/20/6 Case Number & C 13 027 Special Subject OIG special project: Self Title Project: NRC Initiated Regulatory Oversight Date Opened 04/01/2013 Due Date 09/30/2016 Team AIGI Case Agent l(b)(7)(C) ~NRC Report for Period 09/30/2016 Report Type" Initial Ending*

Origination Docllnk: 1 ~

fneaatjon facts:

(b)(?)(C) !Project Update Investigative Plan:

OIG special project to strengthen NRC's efforts to protect public health and safety and the environment by proactively monitoring agency technical and regulatory processes, nuclear industry trends, trade press, as well as other sources identify potential areas in NRC regulatory oversight of licensee. This special project is a continuation of a previous project, OIG Project case number 10-12 .

Case Update:

!(b)(7)(C) I September 30, 2016 Project 13 027 4°' Quarter 2016 Summary Case Update:

(1) Case 16 001 ; NRO Pre-decisional Release of Information: Awaiting review of final CTF memo. CA is re-writing per recent review. ~~~ assisted the CA l(b)(?)(C) lwho is assigned to this case. (C)

(b)(7)(A),(b)(7)(C)

OFFICIAL USE ONLY 1

(b)(?)(A),(b)(7)( C)

OFFICIAL USE ONLY Memos to File Prepared by: !(b)(7)(C) I 04/ 16/2015 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulaitory Oversight Origination Doclink: D (b)

Subject:

Review of Former (7) green books (C)

Report Date: 04/16/2015 Narrative:

w,i .Jl Wl I LTR_FBI_Former LJgreen book review_April 2015.docx

~ Please review. I think the memo should say what the "green books" generally

~ - The green books where primarily meeting notes for meetings with NRC and OIG staff on a variety of issues under the purview of the OIG. In addition, the "green books" contained unclassified information regarding activities related to DOE that was jointly being reviewed by the NRC. OIG's technical review did not app ear to identify any classified information.

(b)(7)(C)

, 4/19/15 Status: Open Allow Other Editors: Edit Authorization :

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION v,11 REOt,,_ UNITED STATES r:i'; wo-,. _

t,'- """

C' NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 0

~

~

~ f V'.,1-: O' "I . . . . . . .

OFFICE OF THE INSPECTOR GENERAL April 21, 2015 MEMORANDUM TO:

FROM: Joseph A. McMillan Assistant Inspector General for Investigations

SUBJECT:

Review of Former NRC .... r_JC?-J(_c _J _ _ _ _ _ ___,!Green Books (b)(7)(C)

On Friday, February 6, 2015, a FBI contact dropped off the former NRC

!CbJC7JccJ !Qreen books (copies.) The FBI requested NRC O.,_l- to- re_v... Iew the green books (copies) to confirm whether thel(b)(?)(C) pett behind classified information.

We have completed our review of the 6 books dated*: (1) December 7, 2004 - July 7, 2005; (2) July 13, 2005 - January 26, 2006; (3) January 26, 2006 - November 20, 2006; (4) November 21 2006 - September 22 2008; (5) September 9, 2008- August 8, 2009; and (6) February 4, 2010 - March 4, 2010. We found nothing classified.

Thank you for bringing these books to our attention.

TWIS DOCUMENT IS THE PROPERTY OF THE NRC. IF LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING .6.GENCY WITHOUT THE PERMISSION OF THE OFFICE OF THE INSPECTOR GENERAL OFFICIAL USE ONLY-OIG INVESTIGATION INFORMATION

OFFICIAL USE ONLY Memos to File PrT!J!Ured by: !(b )(7)(C) I03/2312015 Case

Title:

Special! Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: D

Subject:

LEXIS/NEXIS Social Media Monitoring Trial Report Date: 03/20/2015 Narrative:

MTF wasn't developed Status: Open Allow Other Editors: Edit Authorization:

~Mana~ement]1 j b)/7) C)

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File Prepllred by: !(b)(?)(C) ! 03120/20/S Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink:

Subject:

l(b)(?)(A)

Report Date: 03/20/2015 Narrative:

Moved to case file Status: Open Allow 01her Editors: Edit Authorization :

Request Review:

Approval:

OFFICIAL USE ONLY 1

OFFICIAL USE ONLY Memos to File Prepared by: l(b)(7)(C) I 03/20120/5 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Origination Doclink: E:l

Subject:

l(b)(?)(A)

Report Date: 03/20/2015 Narrative:

Moved to case file

_ _ _..., Concurred by Name Date

!(b)(7)(C) I 04/0312015 12:43 PM Status: Open Allow Other Editors: Edit Authorization :

Request Review:

Approval:

OFFICIAL USE ONLY

(b)(4), (b)(7)(D)

(b)(4), (b)(7)(D)

(b)( 4), (b)(7)(C) , (b)(7)(0 )

OFFICIAL USE ONLY Memos to File Prepared by: !(b)(7)(C) 1 12/19/ 20/4 Case

Title:

Special! Project: NRC Case Nurmber: C 13 027 Regulatory Oversight Origination Doclink: ~

Subject:

Dave LOCHBAUM teleconference summary and subsequent meeting minute notes with OIG management team and agents Report Date: 12/19/2014 Narrative:

l!l ~

MTF_UCSs Top Priorities_Dec 2014-rev 1.docx

......,...,.,,....,....._concurred by Name Date

!(b)(7)(C)  ! 12/1912014 11 :43 AM Concurred by Name Date

.-I(b-)(7.......)(--

C)---,I 12/2812014 07:01 PM Status: Open Allow Other Editors: Edit Authorization :

Request Review:

Approval:

OFFICIAL USE ONLY 1

....___________,!REVIEW l (b)(7)(C)

CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 1 OF 3 PAGES DETAILS Memorandum to File Summary of Contact On December 18, 2014,!(b )(7)(C) l and SA!(b)(?)(C) had a teleconference with Dave LOCH BAUM to discuss several of his concerns.

Below is a table of his concerns and notes from the teleconference. The concerns were tallied from3 sources. The 3 sources were:

l(b )(7)(C) Imeet ing summary from Region Ill's meeting, the December 17, 2014 letter to Mr. Bell, and the information in Case 15-007.

On n<>r<>mber 18, 2014, OIG management (McMILLANl (b )(7)(C) ~- case agents l(b )(7)(C) ll, an~ (b)(?)(C) I b), 7)(C l met to discuss this memo. The items listed in the 3rd column titled "actions" lists the outcomes from th e meeting per the (b) notes.

(7)

(C UCS's Top Priorities Personal NOTES ACTIONS Case 15-007 Prior to rulemaking in the (1) While waiting for the The NRC (i.e. PM or Engineer who 2007/2008 timeframe, the staff had Commission to respond to wrote the SER) deliberately coded a SECY (014-191) paper that allowed LOCH BAU M's letter, "get fire protection licensing actions, like for making all fire protection smart" by reviewing license amendment requests, licensing actions non- regulations, policy and e><emption requests, and license public. However, after ruling (10 procedures related to renewal applications, to be non- CFR 2.390), the Licensees were to public/nonpublic public, even after the 2007 /2008 identify if there was information in information to i111clude: 10 rulemaklng that addressed "how" the licensing material that should be CFR 50.91, 10 CFR 2.390.

and "what" to make public/non- withheld. From Lochbaum's FOIA (2) Review the 5 reports pubic. By not making these records information, he alludes that none of mentioned in LOCHBAUM's publicly available, the NRC violated t he licensing material had letter.

the rules in the Administrative information redacted. Hence, (3) Determine if letter Procedures Act and 10 CFR Part 50 potentially the staff never adjusted addresses both concern s of (i.e. 10 CFR 50.91) to intervene in or their internal procedures to adopt (i) why/why not documents contest the proposed licensing the provisions of the new were marked as non-public action. rule? That is what Lochbaum wants and (ii) was 50.91 the OIG to find out. regulation violated?

(4) Determine if the letter adequately addresses the inconsistencies of UFSARs in ADAMS.

On-site spent fuel storage. UCS In August 2014, Commission No Action wants NRC to make licensees delivered a decision that transfer spent fuel sooner to ISFSl s LOCH BAUM doesn't agree with.

from spent fuel pools due to safety concerns with the pools.

ntlS DOCUMENT IS THE PROPERTY OF THE NRC. IF LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NO'T TO BE Rf PRODUCED OR DISTRIBUTED OUTSIOE THE RECEIVING AGENCY WITHOUT THE PERMISSION Of THE OFFICE Of THE INSPECTOR GENERAL OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: June 2013

l (b)(?)(C) IREVIEW

---

CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 2 OF 3 PAGES Fire protection. UCS said that LOCH BAUM reported that over 40 Put allegation in I[~(?) ~ roject to reactors are not in compliance with reactors still don't meet Appendix R. review GAO repdrr.-1 Appendix R or NFPA 805. NRC continues to give them additional time. Senator Boxter requested a GAO report. GAO completed the report with recommendations. LOCHBAUM believes the NRC has "allowed" a 3rd option (i.e. Fire Watches) to meet Appendix R. He believes this 1is a defacto regulation.

CENR (Cumulative Effects of Non- LOCHBAUM basically told the same Correlate allei?ation tol(b)(?)(C) I regulation) UCS said NRC is not story that!(b)(7)(C) I (b )(?)(A) Iallegation enforcing regulatory requirements l(b 'J(CJ !The one piece of information on fire, earthquake and flooding that seemed to be new was that a issues. Region IVl(b)(7)(C) I (i.e.

LOCHBAUM provided the name), In 2009, accepted the new seismic information without any review by the staff.

Public Access to information. UCS LOCH BAUM reported that Region II Put allegation in~ project to discussed Oconee flooding and that held a public meeting on June 22, review the agency s policy for the Conformitory action letter was 2010, and didn't inform the disclosure to the public of CALs.

withheld from public. In 2012, UCS community that Oconee was under requested all QUO documents. UCS a CAL. LOCHBAUM believes NRC believes NRC hides behind QUO. lied to the public. He provided the In July 2014, UCS reported that NRC names of 2 NRC public relations was withholding all incoming fire folks who agree" with him.

protectlon and emergency planning documents including license amendments and exemptions.

Fukushima Lessons

• UCS said that LOCH BAUM believes the NRC will No action NRC will not protect the public from grant extended time to Licensees relaxation of Fukushima orders. USC when they can't meet orders from said that NRC always approves Fukushima. (i.e. like the Appendix R licensees' request for more time to fire protection requirements.)

orders or relaxation on orders. UCS sees regulatory contracts to be 3 way

• Public, Licensee and NRC.

THIS DOCUMENT IS THE PROPERT'I OF THE NRC. IF LOANED TO ANOTHER AGENCY IT ANO ITS CONTENTS ARE NOT TO BE REPRODUClD OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT THE PERMISSION OF THE OFFICE OF THE INSPECTOR GENERAL OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: June 2013

l(b

...._)(7_)(_C)_ _ _ _ _ _!REVIEW CASE FILE NUMBER 13-027 NRC Office of the Inspector General PAGE 3 OF 3 PAGES USC also believes NRC is violating LOCH BAUM believes there are Add information to Case 15-007 the Administrative Procedures Act inconsistent practices for docketing by barring public access to licensee FSARs. He gave several examples.

proceedings. He gave the example He believes the 10 CFR 2.390 rule is that the FSAR for Watts Bar I and not being followed here either. He SONGs are not in public ADAMS but mentioned that a RIS was issued Watts Bar II is. UCS said that NRC is related to this. He said that Watts Inconsistent in their message of Bar II FSAR was withheld during what QUO is and what is not. licensing issues.

r )(7)(C) r AME I SIGNATURE REVIEWER NAME I SIGNATURE DATE l(b)(7)(C) I THIS DOCUMENT IS THE PROPERTY OF THE NRC. IF LOANED TO ANOTHER AGENCY IT AND ITS CONTENTS ARE NOT TO BE REPRODUCED OR DISTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT THE PERMISSION OF THE OFFICE OF THE INSPECTOR GENERAL OFFICIAL USE ONLY OIG INVESTIGATION INFORMATION OIG/AIGI Form 724 Revised: June 2013

OFFICIAL USE ONLY Chron Note Prepared by:!{b)(7)(C) !05/ 151201i Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: C}

Date: 05/15/2017 l(b)l?J7 Note

Title:

ia_JSummary Note: Duplicate l(b)(7)(E) Read Autholization : [Monitor], [All]

Allow Other EdltOOI:

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(b)(7) ~NRC OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Preparedby: l(b)(7)(C) l or/OJ/10/7 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Docllnk: ~

Date: 12/02/2016 Note

Title:

Windows Surface 4 computer Note: Windows Surface 4 computer. Does not have antivirus on it so take caution if connecting to internet. (b)( )( ) dvises not connecting to internet, and keep wifi turned off.

Purchased Office Home an

• usiness 20 16 which includes Outlook and OneNote. Outlook can be used to examine email PST fi les. Office 2016 One Note comes with a feature that converts hand-written to text. The pen that is specifically designed for the Surface. Password for the computer is!(bl(7l(CJ IPrnduct Key for Office Home and Business 2016 is QNK6F TWFCM FWTYG 68JQK GJFPD.

Read Authorization: [Monitor), [All)

Allow Other Editors: Edlt Autho . .  :

m '~ )~(7~)(C

,...,.,.,,....... R (C)

NR OFFICIAL USE ONLY

OFFICIAL USE ONLY ChronNote Prepared by: l(b)(7)(C) ll/08/20/6 Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office : NRC - E ntire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Docllnk: lJ Date: 11/08/2016 Note

Title:

~ Summary Note: Info put in Quarterly Report l(b)(7)(E) Read Authorization : [Monitor], [All)

Allow Other Edlt01$: Edit Authoriza11H.1+,,.,.,.,,.- ,

(Management], (b){?)(C) l(b)(?)(C ~RC OFFICIAL USE ON LY

OFFICIAL USE ONLY I

Case

Title:

Special Project: NRC Case Number: C 13 027 Regulatory Oversight Program Office: NRC - Entire Fiscal Year: 2013 Team: AIGI Primary Proactive Initiative Classification:

Origination Doclink: _j Date: 10/25/2016 Note

Title:

Proactive Initiative Potential ..,,..,,-,=,.,,,,.,.------, (b)

On 10/25/16.~ spoke with Indian Point (b)(7)(C) i2) asked

.___ _.about the timing of his in-tion report, etc. (see e-maI e ow (b ( J roug up the

• e of a pote ~ n-concurrence by his office on an related URI. A er reading the e-mail,

~ e (b C nd learned the following information:

l~ ha a inaing related to the "Charging Pumps" failing and not being in compliance with the Maintenance Rule.

2~ had completed a "finding packa e" and had submitted it to the Region.

3Tegi'onal Management - including her (bl(7)(Cl and l(b)(?)(C) ldidn 't a

• her finding. RM has been pu~ in ac .

4. (b)(?)(C) said that RM disagreed with ( ( inding because the charging pumps were "impo an o safety," and that the Licensees xpert Panel had deemed that the charging pumps could "run to fail" a certain number of times before they were in violation of the M * . e Rule regulation.

5. (b)(?)(CJ aid that NUMAC 93-01 , which was endorsed by the Licensee , allowed for Expert Panels to make decisions. However, ~ (and the ~ ) agree that the Maintenance Rule d11,1.1:,;::i,.u1,1.L..<:1.1.10W "run to failure." fil.J

6. (bl(?)(CJ aid the Maintenance Rule Regulation has lost it's intent after 20 years of the Licenses persuadin the NRC to relax the implementation of the rule.

7. As of today, (b)(7)(C) 'snot sure ifli~r ) 1will non-concur or not.

Tue 10/25/2016 1:29 PM 11~?) I The report is due within 45 days from the end of the inspection period (October 31) so the due date is no later than November 14. However, we are still resolving several unrelated issues (that should not affect the groundwater feeder) but may affect/change other findings. Then there is this matter of a non-concurrence by our office on an unrelated URI.

The Regional Office was talking about putting a COM plan together for the groundwater finding.

This also needs to be done and approved before we go public. I don't know where this effort stands.

We are working through these issues with the Regional Office one at a time and expect to OFFICIAL USE ONLY

OFFICIAL USE ONLY publish before the due date. But if we do not resolve the URI close out non-concurrence issue, it could talk a few more weeks. If a non-concurrence occurs, the report is placed on hold until the issue is resolved. We will not know for sure if a non-concurrence will occur until the Regional Office sends a copy of the URI close out package.

Call me if you want the long story ... the exit is scheduled for tomorrow .

......,_..........................,rgy Center (Office)

Cell)

Sel From : (b)(7)(C)

To:

r+ir5s'l?v Qctabec 25 2Ql 6 1 -1 z (b)( )(Cl p' nrc.gov>

SubJect: Feeder Hi!(b)(7)(C) l Just wondering when the inspection report, with the "feeder" you provided to us, will be published?

~ i n advance.

~

l(b)(?)(E) Read Authorization: [Monitor), [All)

Allow Other Editors: Edh Authorization:

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l (b)(?)(C)

June 17, 201'6 Project 13 027 2 nd Quarter 2016Summary

gut~:a::;iod, the ~ provide support to the special agent for the following cases. The latest updates are in Or nt,c, (1) Case 16 001 ; NRO Pre-decisional Release of lnformation:; assisted lhe CA l (b)(?)(C) Iwho is assigned to this case. Although It is not categorized as a technical case, the underlying investi ation Is based on technical documents produced by NRO engineers. For this investigation, the i~\ ssisted with the following actions: (1) did ADAM searches for the document prope (C) (3 MLs), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the MLs (i.e. ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined who" actually submitted the document in ADAMS (i.e. l(b)(?)(C) I),

(5) discussed "why" BCs would leave individual names in the document that was publicly released, and (6) research the policy/procedures for the "Open Door Policy" when meeting with a Commissioner.

(b)(?)(A),(b)(?)(C)

(b)(?)(A),(b)(7)( C)

(b)(?)(A), (b)(7)(C)

(5) Case 13-042, Fort Calhoun Proactive Initiative. Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically, 0/G should attempt to determine why the NRG in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

(6) Case 15-028, Indian Point. DIG managementteam, On April 8' 2016 *ll2) r*d a phone conversation with P. BLANCH to review the 7 questions BLANCH asked in e ebruary 2016 letter to Mr. BELL.EJ invited SA!(b)(?)(C) 1- A separate case is in the process of being initiated. To date, the CA has not been named.

(b)(7)(C) ~ . . , .

CA.___ _, and 12,Jmet to discuss the status of this case. CA reported that he Is addressing 2 specific issues (i.e. the tank contents and 2.206 process and lack of a formal letter) and has been reading/following all the additional information BLANCH has summited to OIG since Fall 2015. This includes the "36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

(b)

Additionally, P Blanch called i2i see Chron note) and reported that he was planning on sending Mr. BELL a letter d (I.e. letter was submitted in March 2016 requesting an investigation into (b)

NRC's inadequate oversight at Indian Point. Thereafter, (7) and Deputy AIGI had a phone conversation with BLANCH (see below for specifics of th~c~all.) ~(~\ is waiting for this separate (C

case to be opened and plans to support the named CA.

(7) Case 15 013, St. Lucie MSIV CDBI Inspection. No new update. The following was reported in the last quarter summary, "St. Lucie MSIV failure after Component Design Basis Inspection (COB/), Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component. Additionally, provided a "check off sheet based on the CD.Bl inspection procedure that the Case Agent can use as a guide during his investigation. n (8) Case 15-029, Pilgrim SRV CDBI Inspection. No new update. The following was reported in the last quarter summary, "Pilgrim SRV failure after a GOBI. Provided the Case Agent with 2 MTFs that identify the areas NRG provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the COB/ inspection procedure that- the Case Agent can use as a guide during his investigation. "

(9) Case 16 01b~NRC misuse of Funds. ~ has supported CA l(b)(?)(C) lwith this investigation. kJ assisted by: (1) contacte~ R technical advisor and received confirmation from the staff that both rules that were described in the FRNs have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the information gathered for this case. The FRNs appear to be geared towards changes in the international market. This case includes misuse of funds related to radiation exposure rates. The CA is currently pursuing a copy of the contract.

(b) 10 Case 16-012, NRC inappropriate process for digital control RIS. ~g has supported SA (b)(?)(C) with this investigation. SA has submitted a CTF memo which is pending. l~~r) I assisted by; (1) participated in the interview of the PM, (2) reviewed material for the 1/22/16 public meeting, (3) discussed this area during a meeting with Dave Lochbaum which is documented in a MTF, and (4) met with !(b)(7)(C) t current (b)(?)(C) ndr )(?)(C) l(b)(?)(C) 1* He explained the situation (bl. ex-branch as it relate._ s-to.....,.

th..,.is- ca_s_e__.,.In_ __,

Magnum are several Chron Notes documenting (11) Case 16 016, Indian Point Tritium Leak In'~

with this case.

(7) support activities.

udson River* l~lI c

is supporting c ,.J(b)(?)(C)

On M,1ns, 2016, CA andm l in{erviewed {h~{bX7){C) !tasked with inspecling the tritium leak.ffi.Jwill develop a MTF based on information described during the interview. Also, IW is in the processing of developing a working plan for this case based on SONGS lesson's lea d.

fl On April 6, 2016, CA and rJ had a planning/update meeting on April 6, 2016 and discussed the following:

A. The allegation from, U.S. Senator Kirsten Gillibrand, requested OIG to:

While I know that the NRG has not yet completed its investigation into the specific cause of the most recent leak, it has been brought to my attention that the leak most likely occurred during preparations for the next refueling outage, while waste stream water was moving to the waste storage tank. More troubling are reports that Entergy personnel were aware of related equipment problems as early as 2014, but failed to adequately repair or replace the equipment...... Additionally, I would like information on whether the NRC's resident inspectors at Indian Point we aware of the malfunctioning equipment which caused the most recent leak , and whether it was flagged as a potential issue at any point prior to the discovery of the leak, and why the decision was made not to repair it in 2014.

(b)

B. CA and ;2) reviewed Indian Point (IP) prior inspection reports and learned that one of the 2011 inspection reports referenced the sump pump being questioned in the allegation. Therefore, In NRC Inspection Report dated March 13, 2011 , OIG learned from the report that, (page 10): the NRC noted that "sump pumps required for mitigation

of internal and external flooding were verified by licensee to be satisfactory. Also it stated, "the inspectors reviewed a sample of flood protection equipment testing and maintenance. Documents reviewed by the inspectors are listed in the Supplemental Information Attachment to this report .In Supplemental Information, A-3, Condition Reports, the NRC referenced: CR-IP2-2011-1717, 28 Sump Pump in Fuel Storage Building (FSB}Testing Issues, 4/10/ 11.

C. On March 4, 2016,l(b)(?)(C) I e-mailed to CA that "the name of the sump pump at IP2, thereby contributing to the tritium leak from the reverse osmosis unit is "FSB Sump Pump 28."

D. The inspectors that performed the March 13, 2011 dated inspection were: (b)(?)(C) and l(b)(?)(C)  !. l(b)(?)(C) Iis currently l(b)(?)(C) Iand (b)(?)(C) is currently a l(b)(7)(C) Iin NRO,l(b)(?)(C) I E. The (b)(?)(C) sent to assist with the February 2016 inspection was (b)(?)(C)

(b)(7)(C)

__, rom Division of Reactor Safety.

F. Reviewed Fukushima Lessons Learned website for IP and found no noted concerns with sump pumps.

Next Steps:

1. lnterviewl(b)(7)(C) I- for background information

~:~I (7) to generate questions for CA to ask) 2 . lnterivew!(b)(?)(C 1- the inspector who assisted with site inspection in March 2016

3. Request NRC e-mails for l(b)(7)(C) IDRB),l(b)(7)(C)  !, and l.(b. ......)(""'7)'""'(c..,.)- .....

(inspector).

4. Plant visit to review Corrective Actions.5. Based on items 1-4 above, lnterview*l(b)(l )(C) l~~r) P RB), l(b)(?)(C) ~ andl(b)(?)(C)  !(inspector)

(b) ,.,.,...,.,,,,.,..,,,..,....- -,

On April 7, 2016, CA and (7) interviewed!(b)(?)(C) I- A MTF of the interview is in the case (C) file.

(b)(7)

CC) added Inspection Procedure (IP) 71111 .01 "Adverse Weather Protection" and the March 2011 Inspection Report to the case file. l~\ identified that "corrective action records" are required for review per IP 71111.01 . ~ )

(12) Case 16 014, Fukushima FOIA,~ supported CA l(b)(7)(C) Iby setting up and participating in a meeting with the alleger, Dave LOCHBAUM. Based on the discussion ,

LOCHBAUM might withdraw his allegation. ITsi UzJ prepared a MTF with details and analysis from the meeting.

(b)(?)(A),(b)(7)(C)

(b)

Ourlna this oeriod thE (7) reviewed the followina alleaation assianed to her:

(C I.I....

(b)(?)(A),(b)(?)(C)

(b)(?)(A),(b)(7)( C)

(b)

(3) Allegation 15-07582- UFSAR Public Availability in ADAMS. 12) discussed this allegation with alleger, David LOCHBAUM. The NRC reversed a SECY based on LOCHBAUM's request. To date,~TJ is still working with LOCHBAUM to see if his concern with (C)

UFSARs has been resolved. For mple, DC was just added to ADAMS In March 2016k which Is approximately 1 year since it was docketed in Still monitoring delays in making FSAR publically available.

(4) Allegation 14 07379 - Chrystal River Seismic Concerns. Still working on Closure Memo. No new update. Has been delayed due to priorities. Will try to get to Joe by Nov 10th COB. Region ll's Allegation Review Board's review of seismic concerns with Chrystal River -

The alleger believes the numerous engineering concerns he proved to Region II were not adequately addressed.j<b)(7)(C) lrev~ewed the information provided by the alleger and identified a potential ap in the review process by the engineer who was tasked with assisting with this

. (b) )( ) . , . (b)(7)(C) allegat1on . .___ __.met with engineer to understand the process the engineer followed .

is still in the process of developed a closure MTF for this allegation.

(b)(?)(A),(b )(7)(C)

(b)(7)(A), (b)(7)(C)

~ [ITT (7) Allegation 16 07859 - 1!.cijreviewed the information in Magnum. E'.Jbelieves the NBC has allowed Licensees to modify the plant with licem conditions that are knowingly inadequate to meet NRC guidance. CA has not approachedEJfor support.

(b)(7)(A),(b)(7)(C)

(9) Allegation 16 07800 - To date, this allegation has not been coorelated to this project although the initial review comments states that it should.

Proactive Reviews:

(1) Callaway aux feedpump control failure - Prepared MTF and supporting documents.

Briefed SA who attended December 3, 2015 Region IV counterpart meeting. See Chron note for further details. appears NRC reviewed in ROP inspection this component that ultimately failed. MTF will be drafted if research indicates NRC had a potential lapse in oversight.11~;) lwil follow-up on this allegation next quarter. C

(b)(4), (b)(?)(A ), (b)(?)(C), (b)(?)(D) descri"bed .in Iast QuarterIy summary)

Other event/concerns related to ...._ 1 __

l(b)(f){A)

( as (b )(4 ), (b )(?)(A) , (b)(?)(C), (b )(7)(0)

(b)( 4), (b)(?)(A), (b )(?)(C), (b)(?)(D)

(3) Economic Espionage: n nd CA discussed potential technical interest in new technology.

hl specificaIIy, CA discusse1 small modular reactors (SMR). --

i~l has experience with SMRs and (C)

agreed to set-up a meeting with l(b)(?l(C) 1 l~~f) I spoke wit~ l(b)(7)(C) p n the phone and he agreed to meet. He mentioned that he has worked with NSIR in the past on this subject. Meeting has been set for June 15, 2016.

Ourin this review communicated with the followin Stakeholder Grou s:

(1) Dave Lochbaum - On January 20, 2016. Dave Lochbaum was at NRC HQs and met with (b)(7)(C) I_

l,__ ____.r nd SAl(b)(7)(C) I* The following items were discussed:

• Cancer Study - Industry has decided not to pursue a 2.206 for cancellation of Phase 2 of the cancer study. The study was cancelled during Project AMI. Industry believes they will get better traction with the NRC if they file a contention when a Licensee - who was identified in Phase 1 of the project as high risk - files a licensing action (i.e. LAR, License Renewal, etc.) Phase 2 of the project was to take the results from Phase 1 and understand why these sites were considered high risk. All in all, the results did not have any statistical outliers they were deemed significant but the study did identify some high rate sites. This study was funded by NRC and conducted by NAS. Dave is not aw.are of any "international" or "regulatory changes related to this study as described in Case 16-013.

• The Special Interest Group guru for radiation dose i~_(6_l<7 I

) _ _ _ Dave will e-mail

_l(_c_

his contact information.

• Dave is at HQ today for the public meeting on the RIS for Aging Components. He agrees with NRC's position and hopes they don't change it. Per Dave, the NRC would require "evaluations" - not simple function testing - In order to demonstrate that equipment past its service life is still safe. The industry does not want evaluatio ns to be used as a control point.

• Pale Verde - Dave is visiting the plant in April to see the new "digital controls upgrade" that DOE is partnering with the Licensee to do.

(2) Paul BLANCH - on March 17, 2016, i~] and Deputy AIGI Had a phone conversation with Paul Blanch regarding the letter B ~ ~ ) te to Mr. Bell in March 2016. He alleged NRC's oversight was not appropriate.L Jotes from the meeting include:

A. BLAf'JCH's top 3 issues: (1 ] Violation of MD 8.5 and 8.11 (2.206 Petition), (2) IP operating in an unanalyzed condition, and (3] from Blanch's letter...item #5. Buried portion has never been analyzed. But does it need to be? OIG to check. NRC said (b){7)(C)

(b)(7J(CJ told him, "the above ground portion has been analyzed." Perl~~),(?) lin 2008, it

wasn't analyzed...however, there was an allegation in 2008 about the gas line near the river...800 feet away ..in response to that allegatlon .... NRC responded a rupture won't jepordize the safety structures. But...they didn't seem to analyze the buried portion (in 2010 Paul did a petition) told him they just analyzed the above ground portion.

B. Paul said, We can conclude the NRC has not done an adequate risk assessment....operating in an unanalyzed condition. We can't direct the AGENCY but we could send to the EDO and Commission and hopefully they will take action.

C. Dave Lochbaum - On March 10, 2016,l i lmet with LOCHBAUM. At the meeting, LOCHBAUM shared the following Information:

• He met with the FOIA office regarding his concern with Fukushima FOIA requests. A separate MTF has been developed regarding this topic.

• He discussed his current project which is researching, reviewing, and understanding why NRC has a large number of RAls. He believes industry is putting pressure on NRC to reduce RAls. However, LOCHBAUM is looking into10 CFR 50.9 to see if Licensees are really the ones who need to be accountable for providling complete and accurate information.

• He is waiting for NRC to put all UFSARs back in ADAMS per SECY.

During this period, ~supported DIG efforts to:

(C (1). DOE OIG. l(b)(7)(C) !prepared a presentation for ooEFb)(?)(C) I- The presentation focused on NRC's mission with "DOE/NRC common connections" identified throughout the presentation. The link to the presentation i s listed below.

(b)(7)(C), (b)(7)(D)

(b)(7)(A),(b)(7)(C)

(b)(?)(A),(b)(7)(C)

(b) 7 (3) Training for Special Agents - /2) presented the DOE/NRC power point to _l(b-)(_ _ )(C

_)_ __

request on April 11 . 2016 Part 2 of Reactor Concepts Training was completed on February 4, 2016. All the training material is included in a chron note within 13 027.

Prepared an update to the SA Technical Training Plan and presented during February OIG Strategic Planning Meeting.

Second and third quarter training includes S-201, Materialls Controls, Security Systems and Prin~iples course (taught by TTC Staff) and ADAMS training (in il earn)l m ) l is working with Team Leaders to get folks registered and completion of these courses.

(4) Interface with OIG bAudits -fil] was briefed by l(b)(?)(C) Iregarding the 50.59 audit OIG is conducting.ll2i Isuggested that Audits review all the Special Inspections performed in the last few years and determine if the equipment tha

• ed was (1) previously inspected

J by NRC and/or (2) recently modified under 50.59. Also, \2) suggested Audits review the last 3 years of LERs and determine the same. Hence, 1 t e equipmimb)at failed was (1 )

previously inspected by NRC and/or (2) recently modified under 50.59. (7) also provided information regarding "additional guidance" industry utilizes. Meaning, C 96 07 is not the only guidance used by Licensees. J,; ~lagree to obtain the name of the additional guidance.

Overall, it appears this audit is lea c to many lose ends that appear to impact the effechveness of NRC oversight of 50.59. Also, 50.59 audits might be eliminated per Project AIM. ml b)

(5) Interface with OIG Audits - Materials Teams - (?c) me

• h the Material's team to (b) items related to NRC's oversight of material exports. (7) shared past and current (C) investigation/allegations regarding this subject. The au ,t team will be reaching out (b) t (7) once the team has determined the scope of the audit.

(C)

(6) 0 ed the presentation material discussed in the April 11, 2016 NEA newsletter regarding, "NEA Seminar on Lessons Learnt from the Waste Isolation Pilot Plant (WIPP)." Currently, i~l (C),

is planning to discuss with AIGI the next steps.

The seminar summary states:

Recognizing the importance of safety culture and the impact of managerial and human factors on safety performance in the management of radioactive waste, the NEA held a seminar on 31 March 2016 to examine the lessons learnt from the accidents that occurred at the Waste Isolation Pilot Plant (WIPP) in 2014. Located in southeast New Mexico, the WIPP is the only deep geological repository for permanent disposal of transuranic waste in the United States. In February 2014, two isolated events - a fire and a radiological release - took place at the WIPP, triggering a rigorous accident investigation process. The NEA seminar reviewed the danger of complacency in the workplace and discussed means to create a safety-focused organization. The meeting d;scussions a/so revealed the effectiveness of social media as a communication tool. Participants underlined that emergency communications need to be open and transparent with the public in order to be effective and efficient."

Planned Investigative Activities:

(1) Continue supporting the Case Agents as described above.

(2) Continue working the Allegations as described above.

(3) Continue supporting OIG strategic plan initiatives as described above and by initiating cases from project.

(4) Continue to support the initiative to improve data mining and analytics Other Documents:

DOE Presentation:

7 C:\Users\ TXS7\Documents\XPM igrated FolderJ(b)( )(c ) hNRC_ DOE_March 15 2016.pptx Innovative Activities (b)

(1) (7) working on a global summary of AIGl's use to brief NRC Offices.

(C)

Interviews:

11( b)(7)(A)

l(b)(7)(C) I April 13, 2016 50.59 Recommendations for OIG Audits From SONGS (Case 13 006)

Issue 1. Missed Opportunities During NRC Region IV 2009 Inspection.

• How many other 50.59 inspections "miss" the finding which ultimately result in failures of components A. 50.59 Findings impact on ROP columns?

B. Im pact on Events

a. Review LERs b . Review Special Inspections

c. Compare to NRC Inspection Reports

i. St. Lucie Main Steam Isolation Valve ii. Pilgrim Safety Relief Valve iii. Others Issue 2. AIT Review of SC E's 10 CFR 50.59 Evaluations.

• Licensees use "other" guidance

d. For example, USA Resource Manual Issue 3. NRC Oversight of SONGS UFSAR.

• Appears PM's are doing a "paper/sample check." Does that agree with 10 CFR 50.71(e)

Eng111eering Intern:

Tasks 1 l(b)(?)(A) I- Completed - Sent to TL and CAs on June 8,

'2016 TL electronically approved - awaiting signed copy?

2. Case 16 032 - MTF for USC Article, "Seismic Shift," - Completed - Sent to TL

,md ct.son June 7. 2016 TL electronlcall ao roved. awaitinQ siqned co v?

1 (b)(7)(A)

4. C ~\. 1 1. 032

• MTF for IMC 1245 and IMC 1245 App-endix A- Completed - Sent to TL and CAs on June 13, 2016 - awaited TL review.

S (b)(7)(A) 6.

7.

l(b)(7)(C)

May 12, 2016 Project 13 027 2 nd Quarter 2016Summary Case Update:

During this period , the provide support to the special agent for the following cases. The latest updates are in " pie,"

(b)

(1) Case 16 001 ; NRO Pre-decisional Release of Information: l2) assisted the CA l(b)(?)(C) l who is assigned to this case. Although it is not categorized as a technical case, the underlying investigation is based on technical documents produced by NRO engineers. For this investigation, the~ ssisted with the following actions: (1) did ADAM searches for the document properhes1(3 Mls ), (2) determined the "availability" and "date of release fields" were pertinent to the investigation, (3) sent an e-mail to ADAMS IM and requested the "history" of two of the Mls (i.e. ML14106A344 and ML14097A146), reviewed wed the information in the case file, (4) determined "who" actually submitted the document in ADAMS (i.e. l(b )(?)(C) I>,

(5) discussed "whyNBCs would leave individual names in the document that was publicly released, and (6) research the policy/procedures for the "Open Door Policy when meeting with a Commissioner.

(b )(7)(A),(b )(7)(C)

(b)(7)(A),(b)(7)( C)

(b)(?)(A),(b)(?)(C)

(5) Case 13-042, Fort Calhoun Proactive Initiative. Awaiting for a case to be opened for the the 480 Vac breaker fire event as discussed in the CTF memo. Specifically, 0/G should attempt to determine why the NRG in 2009 did not cite Fort Calhoun for the 480 Vac and related condition reports.

(6) Case 15-028, Indian Point. OIG management team, On April 8, 2016, had a phone conversation with P. BLANCH to review the 7 questions BLANCH asked in e ebruary 2016 letter to Mr. BELL. 1~wi1invited SAl(b)(?)(C) ~ A separate case is in the process of being initiated. To date, the CA has not been named.

CA ~ - and ~ met to discuss the status of this case. CA reported that he is addressing 2 specific issues (i.e. the tank contents and 2.206 process and lack of a formal letter) and has been reading/following all the additional information-BtANCH has summited to OIG since Fall 2015. This includes the "36 questions" BLANCH provided to NRC regarding his concerns with the NRC's approval of a new gas pipeline through the Indian Point site.

(b)

Additionally, P Blanch called i2l (see Chron note) and reported that he was planning on sending Mr. BELL a letter d (i.e. letter was submitted in March 21 requesting an investigation into (b)

NRC's inadequate oversight at Indian Point. Thereafter, (7) an puty AIGI had a phone (b) conversation with BLANCH (see below for specifics of the call.) (7) is waiting for this separate (C) case to be opened and plans to support the named CA.

(7) Case 15 01 3, St. Lucie MSIV CDBI Inspection. No new update. The following was reported in the last quarter summary. "St. Lucie MSIV failure after Component Design Basis Inspection (COB/). Provided the Case Agent with 2 MTFs that identify the areas NRC provided oversight versus the failure of the component. Additionally, provided a "check off sheet" based on the COB/ inspection procedure that the Case Agent can use as a guide during his investigation."

(8) Case 15-029, Pilgrim SRV CDBI Inspection. No new update. The following was reported in the last quarter summary, "Pilgrim SRV failure after a COB/. Provided the Case Agent with 2 MTFs that Identify the areas NRC provided oversight versus the failure of the component.

Additionally, provided a "check off sheet" based on the CDBI inspection procedure that the Case Agent can use as a guide during his investigation."

!ITT I I

l(b)(?)(C)

(9) Case 16 013, NRC misuse of Funds.IE..! has supported CA.__ _ _...,with this Investigation. ~~ assisted by: ( 1) contacted NRR technical advisor and received confirmation from the staff a both rules that were described in the FRNs have been de-funded, (2) pulled Federal Register Notices to see what was included in the 2 pre-ruling making documents and (3) have had several meetings with the CA to review and analyze all the information gathered for this case. The FRNs appear to be geared towards changes in the international market. This case Includes misuse of funds related to radiation exposure rates. The CA is currently pursuing a copy of the contract.

(10) Case 16-012, NRC inappropriate process for digital control RIS. ~ has sup~orted SA

!(b)(?)(C) Iwith this investigation. SA has submitted a CTF memo which is pending.I~~? ) I assisted by; (1) participated in the interview of the PM, (2) reviewed material for the 1/22/16 public meeting, (3) discussed this area during a meeting with Dav chbaum which is (b) documented in a MTF, and (4) met wit, (b)(?)(C) t current OIG 1

2) and ex-Chief of Operating Experience Branch). He explained the situation

• ex-branch as 1t relates to this case. In (b)

Magnum are several Chron Notes documenting (7) support activities.

(11) Case 16 016, Indian Point Tritium Leak in\~ Hudson River. ~~~ is supporting C (b)(?)(C) with this case. (C)

(b)

On Ma 5, 2016, CA and ~2) interviewed the HP Inspector tasked with inspecting the tritium leak 1~~

(C) will develop a MTF based on information described during the interview. Also11~~l is in C

I the processing of developing a working plan for this case based on SONGS lesson's learned.

(b)

On April 6, 2016, CA and (?) had a planning/update meeting on April 6, 2016 and discussed the (C) following:

A. T he allegation from, ... (7_)(C

!(b_)_ _ )_ _ _ _ _ _____.I, requested OIG to:

While I know that the NRG has not yet completed its investigation into the spec;fic cause of the most recent leak, it has been brought to my attention that the leak most fikely occurred during preparations for the next refueling outage, while waste stream water was moving to the waste storage tank. More troubling are reports that Entergy personnel were aware of related equipment problems as early as 2014, but failed to adequately repair or replace the equipment ,, .... Additionally, I would like information on whether ,the NRC's resident inspectors at Indian Point we aware of the malfunctioning equipment which caused the most recent leak , and whether it was flagged as a potential Issue at any point prior to the discovery of the leak, and why the decision was made not to repair it in 2014.

(b)

B. CA and 12) reviewed Indian Point (IP) prior inspection reports and learned that one of the 201 inspection reports referenced the sump pump being questioned in the allegation. Therefore, In NRG Inspection Report dated March 13, 2011 , OIG learned from the report that, (page 10): the NRC noted that "sump pumps required for mitigation

of internal and external flooding were verified by licensee to be satisfactory. Also it stated, "the Inspectors reviewed a sample of flood protection equipment testing and maintenance. Documents reviewed by the inspectors are listed in the Supplemental Information Attachment to this report .In Supplemental Information, A-3, Condition Reports, the NRC referenced: CR-IP2-2011-1717, 28 Sump Pump in Fuel Storage Building (FSB }Testing Issues, 4/ 10/11 .

C. On March 4, 2016,l(b)(?)(C) le-malled to CA that "the name of the sump pump at IP2, thereby contributing to the tritium leak from the reverse osmosis unit is "FSB Sump Pump 28."

l<b)(7)(C)

D. The ins ectors that performed the March 13, 2011 dated Ins ection were~

and (b)(?)(C) (RI ). (b)(?)(C) is current!~ (b)(?)(C) and.,,.

l(b...,.

)(7""')<""

c),.......!===:::;l~is____.

currently a (b)(?)(C) in NRO (b)(?)(C)

E. The (b)(?)(C) sent to assist with the February 2016 inspection was (b)(?)(C)

(b)(?)(C) ram Division of Reactor Safety.

F. Reviewed Fukushima Lessons Learned website for IP and found no noted concerns with sump pumps.

Next Steps:

1. lntervie ""(b (7"""

'"")""' )(""

C.,.. I

) - - ._ for background information 11a to generate questions for CA to ask)

2. lnterivew (b)(?)(C) - the inspector who assisted with site inspection in March 2016

3. Request NRC e-mails for ... l(b_)(_7l_

(c_) _ _IDRB), l(b)(?)(C)

(inspector).

4. Plant visit to review Corrective Actions.5. Based on items 1-4 above, lnterview:l(b)(?)(C) ll2l I DRB), l(b)(?)(C) I. andl(b)(?)(C) I(inspector)

On April 7, 2016, CA and i~~ interviewedl(b)(?)(C) A MTF of the interview 1s in the case (C) file.

(b) 1g dded Inspection Procedure (IP) 71111 .01 "Adverse Weather Protection" and the March 1 Inspection Report to the case file ~~~ identified that "corrective action records" are required for review per IP 71111 .01 . (C)

(b)

(12) Case 16 014, Fukushima FOIA, <7l supported (C) cAj(b

)(?)(C) Iby setting up and participating in a meeting with the alleger, Dave LOCHBAUM. Based on the discussion, Nole: The remaining page*s of this 2dQuarler 2016 Report, dated May 12, 2016 are identical to lhe enlrie~ found un lhe 2dQuarter 2016 Repurl, dated June 17, 2016 (which appear immediately before this report).