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{{#Wiki_filter:NRC FORM NRC      FORM 757  757                                                                               u.s. NUCLEAR REGULATORY U.S. NUCLEAR   REGULATORY COMMISSION COMMISSION NRC MD NRC  MD 10.158 10158 (3-2009)
{{#Wiki_filter:NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRC MD 10158 (3-2009)
(3*2009)
NON-CONCURRENCE PROCESS SECTION A - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL TITLE OF DOCUMENT ADAMS ACCESSION NO.
NON-CONCURRENCE PROCESS SECTION A SECTION          A - TO
St. Lucie Inspection Reøort 05000389/2010003 DOCUMENT SPONSOR SPONSOR PHONE NO.
                      - TO BEBE COMPLETED COMPLETED BY BY NON-CONCURRING        INDIVIDUAL NON-CONCURRING INDIVIDUAL TITLE OF TITLE      OF DOCUMENT DOCUMENT                                                                                               ADAMS ADAMS ACCESSION NO. NO.
Mark Franke 404-997-4436 NAME OF NON-CONCURRING INDIVIDUAL PHONE NO.
Inspection Report St. Lucie Inspection                   05000389/2010003 Reøort 05000389/2010003 DOCUMENT SPONSOR DOCUMENT            SPONSOR                                                                                            SPONSOR SPONSOR PHONEPHONE NO.
Walt Rogers 404-997-4619 DOCUMENT AUTHOR DOCUMENT CONTRIBUTOR DOCUMENT REVIEWER ON CONCURRENCE TITLE ORGANIZATION Senior Reactor Analyst DRS/EB2 REASONS FOR NON-CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance. The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivties.
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Mark Franke Mark         Franke                                                                                                           404-997-4436 404-997-4436 NAME OF NAME      OF NON-CONCURRING          INDIVIDUAL NON-CONCURRING INDIVIDUAL                                                                             PHONE PHONE NO. NO.
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Walt Rogers                                                                                                                   404-997-4619 D      DOCUMENT AUTHOR DOCUMENT           AUTHOR         D    DOCUMENT CONTRIBUTOR DOCUMENT                        D    DOCUMENT REVIEWER DOCUMENT    REVIEWER        ~    ON ON CONCURRENCE TITLE TITLE                                                                    ORGANIZATION Senior Reactor Analyst                                                   DRS/EB2 IDRSlEB2 REASONS FOR NON-CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance. The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivtiesactiivties..
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~ ON CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance. The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivties.  
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NRC FORM 757 (3-2009)
Use ADAMS Template NRc'()06 PRINTED ON RECYCLED PAPER


NRC FORM 757 NRC                                                                                                        NUCLEAR REGULATORY COMMISSION U.S. NUCLEAR 10.158 NRC MD 10.158 (3-2009)
NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRC MD 10.158 (3-2009)
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT                                                                                                       IADAMS ACCESSION NO.
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT ADAMS ACCESSION NO.
05000389/2010003 St. Lucie Inspection Report 0500038912010003 SECTION B - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S
St. Lucie Inspection Report 05000389/2010003 SECTION B - TO BE COMPLETED BY NON-CONCURRING INDMDUALS SUPERViSOR (THIS SECTION SHOULD ONLY BE COMPLETED IF SUPERVISOR IS DIFFERENT THAN DOCUMENT SPONSOR.)
                -                                                      INDMDUALS SUPERViSOR SUPERVISOR (THIS SECTION SHOULD ONLY BE            BE COMPLETED IF                           DIFFERENT THAN DOCUMENT SPONSOR.)
NAME Rebecca L. Nease TITLE PHONE NO.
IF SUPERVISOR IS DIFFERENT NAME Rebecca L. Nease TITLE                                                                                                                   PHONE NO.
Chief, Engineering Branch 2 404-997-4530 ORGANIZATION Division of Reactor Safety, Region II COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER I HAVE NO COMMENTS I HAVE THE FOLLOWING COMMENTS I have reviewed the attached documentation, and it appears that all parties have acted in good faith, to consider all views with repsect to the subject of this non-concurrence. At issue is whether is is appropriate to use the shutdown operations significnce determination process (SDP) or the at-power SDP for the described performance deficiency. While a conclusion was reached that shutdown risk was not to be considered, it appears that this was not a consensus view among the staff in NRR and Region II. In addition, it appears that the guidance could have supported either view, depending on which part of the guidance was referenced. This ambiguity does not speak well for our principals of good regulation, especially the principal of clarity.
Cbief, Engineering Brancb
Having reviewed the documents attached herein, and read each view, either methodology (shutdown risk or at-power risk) appears to meet at least some parts of the guidance. However, in using shutdown risk to conclude a higher risk level, we would have had the opportunity (within the guidance) to send a strong message to the licensee that repeatedly entering a risk-signficant plant configuration to fix the same or similar degraded condition is not in the interest of safety.
: Chief, ORGANIZATION ORGANIZATION Branch 2                                                                                   I      404-997-4530 Division of Reactor Safety. Safety, Region IID COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER D      II HAVE HAVE NO COMMENTS
I believe the confusing guidance bears revision to provide clarity to the process and to permit such latitide in egregious cases, such as this one.
                !ill  II HAVE THE FOLLOWING COMMENTS I have bave reviewed the   tbe attacbed attached documentation, and it appears that tbat all parties have                 faitb, to consider all views bave acted in good faith, witb repsect to the with                  tbe subject of tbis this non-concurrence. At issue is whether wbetber is is appropriate to use the     shutdown operations tbe sbutdown significnce determination process (SDP) or the         tbe at-power SDP for tbethe described performance deficiency. While a conclusion reacbed tbat was reached       that sbutdown shutdown risk was not to be considered, it appears that       this was not a consensus view among the tbat tbis                                        tbe staff in NRR and Region II.          D. In addition, it appears tbat                        have supported eitber tbe guidance could bave that the                                    either view, depending on which   wbicb part of tbe the guidance was referenced. Tbis      This ambiguity does not speak well for our principals of good regulation, especially tbe        the principal of clarity.
CONTINUED IN SECTION D SIGNAT E
Having reviewed tbe        the documents attacbed attached berein,             each view, eitber herein, and read eacb          either metbodology  (shutdown risk or at-power risk) methodology (sbutdown appears to meet at least some parts oftbe                                              shutdown risk to conclude a bigber of the guidance. However, in using sbutdown                              higher risk level, we would havebave hadbad tbe the opportunity (witbin (within tbe the guidance) to send a strong message to tbe the licensee tbat that repeatedly entering a risk-signficant plant configuration to fIX      fix tbe the same or similar degraded condition is not in tbe the interest of safety. I believe tbe    the confusing guidance bears revision to provide clarity to tbe        the process and to permit sucb such latitide in egregious cases, sucb          this such as tbis one.
DATE 7/43//d SUBMIT THIS PAGE TO DOCUMENT SPONSOR NRC FORM 757 (3-2009)
D CONTINUED CONTINUED IN SECTION D       D Ii ~
Use ADAMS Template NRC.006 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD 10.158 (3-2009)
SIGNAT E                                                                                                           DATE SIGNAfLr1l/l v
U.S. NUCLEAR REGULATORY COMMISSION NON-CONCURRENCE PROCESS TITLE OF DOCUMENT St. Lucie Inspection Report 0500038912010003 I ADAMS ACCESSION NO.
7/43//d
SECTION B - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S SUPERVISOR (THIS SECTION SHOULD ONLY BE COMPLETED IF SUPERVISOR IS DIFFERENT THAN DOCUMENT SPONSOR.)
                                                                                                                          ". I     I SUBMIT THIS PAGE TO DOCUMENT SPONSOR NRC FORM FORM 757 (3-2009)                                     Use ADAMS Template NRC.006 NRC-D06                                   PRINTED ON RECYCLED PAPER
NAME Rebecca L. Nease TITLE Cbief, Engineering Brancb 2 ORGANIZATION Division of Reactor Safety. Region D COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER D I HAVE NO COMMENTS
!ill I HAVE THE FOLLOWING COMMENTS I
PHONE NO.
404-997-4530 I bave reviewed tbe attacbed documentation, and it appears tbat all parties bave acted in good faitb, to consider all views witb repsect to tbe subject of tbis non-concurrence. At issue is wbetber is is appropriate to use tbe sbutdown operations significnce determination process (SDP) or tbe at-power SDP for tbe described performance deficiency. While a conclusion was reacbed tbat sbutdown risk was not to be considered, it appears tbat tbis was not a consensus view among tbe staff in NRR and Region D. In addition, it appears tbat tbe guidance could bave supported eitber view, depending on wbicb part of tbe guidance was referenced. Tbis ambiguity does not speak well for our principals of good regulation, especially tbe principal of clarity.
Having reviewed tbe documents attacbed berein, and read eacb view, eitber metbodology (sbutdown risk or at-power risk) appears to meet at least some parts oftbe guidance. However, in using sbutdown risk to conclude a bigber risk level, we would bave bad tbe opportunity (witbin tbe guidance) to send a strong message to tbe licensee tbat repeatedly entering a risk-signficant plant configuration to fIX tbe same or similar degraded condition is not in tbe interest of safety. I believe tbe confusing guidance bears revision to provide clarity to tbe process and to permit sucb latitide in egregious cases, sucb as tbis one.
D CONTINUED IN SECTION D SIGNAfLr1l/l Ii ~
v SUBMIT THIS PAGE TO DOCUMENT SPONSOR  
". I I
NRC FORM 757 (3-2009)
Use ADAMS Template NRC-D06 PRINTED ON RECYCLED PAPER  


,    NRC FORM NRC     FORM 757 NRC MD10.158 NRC  MD 10158 (3-2009) 757                                                                                                        U.S.
NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRC MD 10158 (3-2009)
U.S. NUCLEAR NUCLEAR REGULATORY REGULATORY COMMISSION COMMISSION (3-2009)
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT St Lucie Inspection Report 05000389/2010003 SECTION C
NON-CONCURRENCE PROCESS NON~ONCURRENCEPROCESS TITLE OF TITLE      OF DOCUMENT DOCUMENT                                                                                                                                  IADAMS ADAMS ACCESSION ACCESSION NO. NO.
- TO BE COMPLETED BY DOCUMENT SPONSOR NAME Mark Franke ADAMS ACCESSION NO.
St Lucie 8t    Lucie Inspection Inspection Report    Report 05000389/2010003 05000389/2010003
TITLE PHONE NO.
                                                                                          -----------------------------------~I-------------------
Branch Chief 404-997-4436 ORGANIZATION DRS/EB3 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised, as necessary, to reflect the final outcome of the non-concurrence process, including a complete discussion of how individual concerns were addressed.)
SECTION CC - TO SECTION                      -      BE COMPLETED TO BE    COMPLETED BY          DOCUMENT SPONSOR BY DOCUMENT            SPONSOR NAME
The issue at the heart of this non-concurrence is whether it is appropriate to assess shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed seal line finding.
                                                                                            -------------
I believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and NRR DIRS and DRA.
NAME Mark Franke Mark        Franke TITLE TITLE                                                                                                                                                          PHONE PHONE NO.NO.
On March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix C, Shutdown Operations Significance Determination Process, should not be used to evaluate this finding and stated that NRRIDRA did not believe this performance deficiency affected operations during shutdown conditions. Lois James referenced IMC 0609, the RASP Handbook, and a review of past findings as the basis for this decision. Her email of 3/3/20 10 describes this argument and it is attached.
Branch Chief Branch          Chief                                                                                                                                                  404-997-4436 ORGANIZATION I        404-997-4436 ORGANIZATION DRS/EB3 DRSlEB3
Additional meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, came to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance Assessment Branch, expressed concern over the whether it was programmatically appropriate and consistent to use Appendix G for this finding considering that the finding occurred At-power.
  -ACTIONS  - -TAKEN ACTIONS TAKEN
On April 30, 2010, after considering all of the perspectives, John Lubinski (acting DRS director) determined that it was consistent with our process and practice to process to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix C risk assessment. It would screen out per IMC 0609 Phase 1 screening. To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with the licensees shutdown operations or maintenance risk managment.
                            - -TO      -ADDRESS
(Reference Lubinski email 4/30/10, attached).
                                          -
Rani Franovich, Chief of Performance Assessment, agreed with this decision via email on 6/4/201 0.
TO ADDRESS      NON-CONCURRENCE (This NON-CONCURRENCE            (This section section should should bebe revised revised,, as necessary, to as necessary,  to reflect reflect the the final final outcome outcome ofof the the non-concurrence process, non-concurrence                  process, including including aa complete complete discussion discussion ofof how  individual concerns how individual    concerns were were addressed.)
I have reviewed this non-concurrence documentation in detail. It illustrates the numerous important arguments and counter-arguments that the staff discussed and highlights several areas for potential SDP guidance clarification. Because I believe that these arguments were thoughtfully considered in the April 30 decision, I do not propose reversing that decision.
addressed.)
The performance deficiency was not viewed to extend into the licensees decisions to shutdown and repair. To address staff division and concerns over this, DIRS initiated an effort to examine whether changes were needed in NRC procedures to ensure clarity, reliability, and efficiency going forward. DIRS initiated an ROP feedback form to track this effort.
The issue at The                  at the heart of this      this non-concurrence non-concurrence is whether it           it is appropriate to assess shutdown shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed                    failed seal line finding.
(Reference Franovich email 6/4/10) I believe, on balance, that the decisions to treat this finding as an At-Power finding and to conduct a review of our guidance are in the interests of ROP reliability and clarity, which are in the the public interest.
II believe believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and  and NRR DIRS and DRA.
This path also provides for additional stakeholder participation and communication should SDP guidance revisions occur.
On March On    March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix G,                                                                  C, Shutdown Operations Significance Determination                Determination Process, should not be used to evaluate this finding and stated that NRRIDRA did not believe this performance deficiency affected operations during shutdown conditions. Lois James NRRlDRA referenced IMC 0609 ,, the RASP Handbook, and a review of past findings as the basis for this decision. Her email of 3/3/20 10 describes this argument and it is attached.
/
3/3/2010 Additional Additional meetings        meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, perpectives.
NON-CONCURS WITHDRAWS NON-CONCURRENCE (i.e., discontinues process)
came to   to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance                                          Performance Assessment Assessment Branch, expressed              expressed concern over the whether   whether it was programmati programmatically  cally appropriate and consistent to use            use Appendix Appendix G            G for this finding considering considering that the finding occurred At-power.
CONTINUED IN SECTION D DAT
On April April 30,    30, 2010,  2010, after considering all    all of  the perspectives, of the   perspectives, John Lubinski  Lubinski (acting DRS director) determined that it was consistent consistent with our              our process and practice practice to process to    to treat thisthis as as an At-Power finding. In other words,         words, we would not      not view this this asas aa finding finding warranting an Appendix C                    G risk assessment. It          would screen out It would              out per per IMC 0609 0609 Phase Phase 11 screening. To      To perform perform maintenance maintenance to          to correct correct the the leak, leak, the the licensee licensee shutdown shutdown and entered    entered reduced reduced inventory inventory operation.
/WANTS NCP FORM PUBLIC WANTS NCP FORM NON-PUBLIC CONCURS process is complete, i.e., after document is signed):
operation. We    We did did not not identify identify performance performance deficiencies  deficiencies associated associated withwith the the licensees licensee's shutdown shutdown operations operations or  or maintenance maintenance risk managment.managment.
NRC FORM 757 (3-2009)
(Reference (Reference Lubinski      Lubinski email email 4/30/10, 4/30110, attached).
Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD10.158 (3-2009)
attached). Rani  Rani Franovich, Franovich,Chief  Chief of of Performance Performance Assessment, agreed        agreed withwith this decision decision via email via    email on      on 6/4/2016/4/2010. 0.
TITLE OF DOCUMENT NON~ONCURRENCEPROCESS U.S. NUCLEAR REGULATORY COMMISSION IADAMS ACCESSION NO.
II have have reviewed reviewed this          this non-concurre non-concurrence  nce documentatio documentation      n in in detail.
8t Lucie Inspection Report 05000389/2010003
detail. It    illustrates the It illustrates    the numerous numerous important important arguments arguments and  and counter-argu counter-arguments            ments that that the    staff discussed the staff  discussed and and highlights highlights several several areasareas for for potential potential SDPSDP guidance guidance clarification.
-----------------------------------~I-------------------
clarification. Because Because II believe believe that  that these    these arguments arguments were were thoughtfully thoughtfully considered considered in    in the the April April 3030 decision, decision, II do do not not propose propose reversing reversing thatthat decision.
SECTION C - TO BE COMPLETED BY DOCUMENT SPONSOR NAME Mark Franke TITLE Branch Chief ORGANIZATION DRSlEB3 I
decision.
PHONE NO.
The performance The    performance deficiency        deficiency was was not not viewed viewed to  to extend extend intointo the the licensees licensee's decisions decisions to  to shutdown shutdown and  and repair.
404-997-4436 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised, as necessary, to reflect the final outcome of the non-concurrence process, including a complete discussion of how individual concerns were addressed.)
repair. To  To address address staff staff division division and   and concerns  concerns overover this, this, DIRS DIRS initiated initiated an an effort effort toto examine examine whether whether changes changes werewere needed needed in  in NRC NRC procedures procedures to  to ensure clarity, ensure        clarity, reliability,               and efficiency reliability, and    efficiency going going forward.
The issue at the heart of this non-concurrence is whether it is appropriate to assess shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed seal line finding.
forward. DIRS DIRS initiated initiated an an ROP ROP feedback feedback formform to to track track thisthis effort.
I believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and NRR DIRS and DRA.
effort.
On March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should not be used to evaluate this finding and stated that NRRlDRA did not believe this performance deficiency affected operations during shutdown conditions. Lois James referenced IMC 0609, the RASP Handbook, and a review of past findings as the basis for this decision. Her email of 3/3/2010 describes this argument and it is attached.
(Reference (Reference Franovich      Franovich email          6/4/10) II believe, email 6/4/10)      believe, on on balance, balance, that that the the decisions decisions to  to treat treat this this finding finding as as an an At-Power At-Power finding finding and and to to conduct conduct aa review        review ofofour our guidance guidance are are inin the the interests interests of of ROP ROP reliability reliability andand clarity, clarity, which which areare inin the the the the public public interest.
Additional meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, came to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance Assessment Branch, expressed concern over the whether it was programmatically appropriate and consistent to use Appendix G for this finding considering that the finding occurred At-power.
interest.
On April 30, 2010, after considering all of the perspectives, John Lubinski (acting DRS director) determined that it was consistent with our process and practice to process to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. It would screen out per IMC 0609 Phase 1 screening. To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with the licensee's shutdown operations or maintenance risk managment.
This path This    path also    also provides provides forfor additional additional stakeholder stakeholder participation participation and   and communicati communication        should SDP on should      SDP guidance guidance revisions revisions occur.
(Reference Lubinski email 4/30110, attached). Rani Franovich,Chief of Performance Assessment, agreed with this decision via email on 6/4/2010.
occur.
I have reviewed this non-concurrence documentation in detail. It illustrates the numerous important arguments and counter-arguments that the staff discussed and highlights several areas for potential SDP guidance clarification. Because I believe that these arguments were thoughtfully considered in the April 30 decision, I do not propose reversing that decision.
D CONTINUED CONTINUED IN    IN SECTION SECTION DD tsSTGiI~
The performance deficiency was not viewed to extend into the licensee's decisions to shutdown and repair. To address staff division and concerns over this, DIRS initiated an effort to examine whether changes were needed in NRC procedures to ensure clarity, reliability, and efficiency going forward. DIRS initiated an ROP feedback form to track this effort.
GN~.-~  : : : : :. .- --m{~
(Reference Franovich email 6/4/10) I believe, on balance, that the decisions to treat this finding as an At-Power finding and to conduct a review of our guidance are in the interests of ROP reliability and clarity, which are in the the public interest.
                              '?:' ~    ~ij&#xa5;SPOJ~'~$*~~~cr=-rDDA~:TIT~~'Z-~;;,/,l"-11W@YA~51G"~                                                                        1';;Zb (;0 DAT NON-CONCURRING INDIVIDUAL (To be completed by documerl sponsor when process                                              process isis complete, complete, i.e.,
This path also provides for additional stakeholder participation and communication should SDP guidance revisions occur.
i.e., after after document document isis signed):
D CONTINUED IN SECTION D tsSTGi II~
signed):
GN~.--::::::~
D      CONCURS CONCURS                                                                              c6
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                                                                                                                                /WANTSWANTS NCP NCP FORM FORM PUBLIC PUBLIC o/      NON-CONCURS NON-CONCURS                                                                          D    WANTS WANTS NCP NCP FORM FORM NON-PUBLIC NON-PUBLIC D      WITHDRAWS W ITHDRAWS NON-CONCURRENCE NON-CONCURRENCE (i.e.,      (Le.,discontinues discontinuesprocess) process)
~ij&#xa5;SPOJ~'~$*~~~cr=-rDDA~:TIT~~
NRC  FORM757 NRCFORM        757 (3-2009)
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(3-2009)                                        Use UseADAMS ADAMS Template TemplateNRC-006 NRC-D06                                                 PRINTEDON PRINTED ONRECYCLED RECYCLEDPAPER PAPER
~;;,/,l"-11W@YA~ 51G"~ 1';;Zb (;0 NON-CONCURRING INDIVIDUAL (To be completed by documerl sponsor when process is complete, i.e., after document is signed):
D CONCURS o NON-CONCURS D W ITHDRAWS NON-CONCURRENCE (Le., discontinues process)
NRC FORM 757 (3-2009)
Use ADAMS Template NRC-D06 c6 WANTS NCP FORM PUBLIC D WANTS NCP FORM NON-PUBLIC PRINTED ON RECYCLED PAPER  


Lo         -LQA Franke, Mark Franke,    Mark From:
Lo -LQA Franke, Mark From:
From:                              Nease, Rebecca Nease,    Rebecca Sent:
Nease, Rebecca Sent:
Sent:                              Friday, March Friday,   March 05, 05, 20102:34 2010 2:34 PM  PM To:                                 Franke, Mark; Vargas, Franke,            Vargas, Alexandra
Friday, March 05, 2010 2:34 PM To:
Franke, Mark; Vargas, Alexandra


==Subject:==
==Subject:==
FW: SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line Leak NRRs basis for not using App G.
From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie


==Subject:==
==Subject:==
FW: SDP Phase FW:                      Analysis Of St.
SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line Leak
Phase 3 Analysis                  Lucie Rep St. Lucie   RCP Seal Leak-Off Leak-Off Line Line Leak Leak NRRs basis NRR's  basis for notnot using using App G. G.
: Rebecca, The Probabilistic Risk Assessment Operational Support Branch (APOB) was requested by Engineering Branch 2 in the Division of Reactor Safety in Region II to perform a Phase 3 Significance Determination Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) required unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance deficiency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld.
From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM Sent:
APOB staff forwarded the Phase 3 SDP to Region II staff on February 24, 2010.
To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie
During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place. Clearly, the performance deficiency caused a TS require unit shutdown, however, the performance deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRR/DRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding.
In addition, NRR/DRA believes that this performance deficiency does not affect the operations during shutdown conditions and that available guidance provides that IMC 0609, Appendix G, is applicable to finding that affect the operations during shutdown conditions.
IMC 0309 Appendix G, Shutdown Operations Significance Determination Process (IMC 0609, App G), states that:
o For deficiencies occurring above the RHR entry conditions, the full power SDP tools should be used...[section 2.1]
o An initiating event at shutdown is defined as an event that causes a loss or interruption of the decay heat removal function. [section 4.0]
IMC 0609 Attachment 4 provides guidance that performance deficiencies during shutdown modes to be evaluated using Appendix G:
o IF the finding affects: the safety of a reactor during refueling outages, forced outages, and maintenance outages starting, when the licensee has met the entry conditions for RHR and RHR cooling has been initiated, THEN STOP. Go to IMC 0609, Appendix G.
The RASP Handbook provides a specific exception when repair time should not be included in the exposure time to deal with this type of finding:
o If the plant is shutdown and the deficiency only affects an at-power condition, then repair time should not be included 1
Franke, Mark From:
Sent:
To:  


==Subject:==
==Subject:==
SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line                  Line Leak
Nease, Rebecca Friday, March 05, 20102:34 PM Franke, Mark; Vargas, Alexandra FW: SDP Phase 3 Analysis Of St. Lucie Rep Seal Leak-Off Line Leak NRR's basis for not using App G.
: Rebecca, The Probabilistic Risk Assessment Operational Support Sranch                      Branch (APOS)
From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie
(APOB) was requested by Engineering Branch 2 in the Division of Reactor Safety in Region II to perform a Phase 3 Significance Determination Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) required unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance deficiency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld.                                  J-weld.
APOB APOS    staff  forwarded      the  Phase    3  SDP      to  Region II staff on February 24, 2010.
During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place.
place. Clearly, the performance deficiency caused aa TS require unit shutdown, however, the performance deficiency, deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRR/DRA NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Significance Determination Process, should be used to evaluate this finding.
In addition, NRRlDRA NRR/DRA believes that this performance  performance deficiency does not          not affect the operations during shutdown conditions conditions and that available guidance provides that IMC 0609, Appendix G, is applicable to finding that affect the operations during shutdown conditions.      conditions.
* IMC IMC 0309 Appendix G,        G, Shutdown Operations Significance Determination    Determination Process (IMC    (IMC 0609, 0609, App App G),  states that:
G), states    that:
oo For For deficiencies deficiencies occurring occurring aboveabove the  the RHR RHR entry entry conditions, thethe full full power power SDP SDP tools tools should should be  be used.
used ....[section
                                                    . [section 2.1]
2.1]
oo  An initiating An    initiating event event at  at shutdown shutdown is    is defined defined as  as an  event that an event  that causes causes aa loss loss or or interruption interruption of of the the decay decay heat heat removal removal function. [section [section 4.0]4.0]
* IMC    0609 Attachment IMC 0609        Attachment 44 provides provides guidance guidance that  that performance performance deficiencies deficiencies during during shutdown shutdown modes modes to be  evaluated      using  Appendix to be evaluated using Appendix G:             G:
oo IFIF the the finding finding affects:
affects: the  the safety safety of  of aa reactor reactor during during refueling refueling outages, outages, forced forced outages, outages, and and maintenance maintenance outages outages starting,        when the starting, when        the licensee licensee has has met met the the entry entry conditions conditions for for RHR RHR and and RHR RHR cooling cooling has has been been initiated, initiated, THENTHEN STOP.
STOP. Go Go to to IMC IMC 0609, 0609, Appendix Appendix G. G.
          **    The The RASP RASP Handbook Handbook provides provides aa specific specific exception exception when when repair repair time time should should not not be be included included in in the the exposure exposure time  time toto deal  with this deal with      this type type ofof finding:
finding:
oo IfIf the the plant plant isis shutdown shutdown and    and the the deficiency deficiency only only affects affects an an at-power at-power condition, condition, then then repair repair time time should should notnot bebe included included 11


Further, NRRlDRA Further. NRR/DRA performed performed aa quick quick search search of   findings on of findings  on the Dynamic Webs the Dynamic  Webs Page Page toto identify identify findings findings that that were found were    found at-power at-power andand included included risk risk insights insights from from IMC IMC 0609 0609 Appendix Appendix G,G, Shutdown Operations Significance Shutdown     Operations     Significance Determination Process.
==Subject:==
Determination        Process. No  No findings findings were were identified identified that that applied applied IMC IMC 0609 0609 Appendix Appendix G   G toto an an at-power at-power finding.
SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line Leak
finding.
: Rebecca, The Probabilistic Risk Assessment Operational Support Sranch (APOS) was requested by Engineering Branch 2 in the Division of Reactor Safety in Region II to perform a Phase 3 Significance Determination Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) required unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance deficiency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld.
We    could  only  locate  items We could only locate items that    that used used IMC IMC 0609 0609 Appendix Appendix G      when the C when   the items items were were identified identified during during shutdown.
APOS staff forwarded the Phase 3 SDP to Region II staff on February 24, 2010.
shutdown.
During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place. Clearly, the performance deficiency caused a TS require unit shutdown, however, the performance deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding.
In conclusion, In    conclusion, while while the   PRA analysis the PRA    analysis completed completed thatthat was was forwarded forwarded toto your your staff staff on on February February 24, 24, 2010, 2010, is is technically adequate technically    adequate in  in calculating calculating the the risk risk associated associated with with reduced reduced inventory, inventory, NRRlDRA NRR/DRA does  does not believe that not  believe  that IMC 0609 IMC     0609 Appendix G,       Shutdown Operations G, Shutdown     Operations Significance Significance Determination Determination Process, Process, should be should    be used used toto evaluate evaluate this finding.
In addition, NRRlDRA believes that this performance deficiency does not affect the operations during shutdown conditions and that available guidance provides that IMC 0609, Appendix G, is applicable to finding that affect the operations during shutdown conditions.
this  finding.
IMC 0309 Appendix G, Shutdown Operations Significance Determination Process (IMC 0609, App G), states that:
IfIf you you would like like to to discuss this this further, further, please please feel feel free free to contact contact me.
o For deficiencies occurring above the RHR entry conditions, the full power SDP tools should be used... [section 2.1]
me.
o An initiating event at shutdown is defined as an event that causes a loss or interruption of the decay heat removal function. [section 4.0]
Lois James, Lois    James, Chief Chief PRA Operational Support (APOB)
IMC 0609 Attachment 4 provides guidance that performance deficiencies during shutdown modes to be evaluated using Appendix G:
Division of Risk Assessment (ORA)    (DRA)
o IF the finding affects: the safety of a reactor during refueling outages, forced outages, and maintenance outages starting, when the licensee has met the entry conditions for RHR and RHR cooling has been initiated, THEN STOP. Go to IMC 0609, Appendix G.
Office of Nuclear Reactor Regulation (NRR) 301-41 5-3306 301-415-3306 lois. ja lois. mes(nrc. qov james@nrc.gov 22
The RASP Handbook provides a specific exception when repair time should not be included in the exposure time to deal with this type of finding:
o If the plant is shutdown and the deficiency only affects an at-power condition, then repair time should not be included 1
 
Further, NRR/DRA performed a quick search of findings on the Dynamic Webs Page to identify findings that were found at-power and included risk insights from IMC 0609 Appendix G, Shutdown Operations Significance Determination Process.
No findings were identified that applied IMC 0609 Appendix G to an at-power finding.
We could only locate items that used IMC 0609 Appendix C when the items were identified during shutdown.
In conclusion, while the PRA analysis completed that was forwarded to your staff on February 24, 2010, is technically adequate in calculating the risk associated with reduced inventory, NRR/DRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding.
If you would like to discuss this further, please feel free to contact me.
Lois James, Chief PRA Operational Support (APOB)
Division of Risk Assessment (DRA)
Office of Nuclear Reactor Regulation (NRR) 301-41 5-3306 lois. james(nrc.qov 2
Further. NRRlDRA performed a quick search of findings on the Dynamic Webs Page to identify findings that were found at-power and included risk insights from IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. No findings were identified that applied IMC 0609 Appendix G to an at-power finding.
We could only locate items that used IMC 0609 Appendix G when the items were identified during shutdown.
In conclusion, while the PRA analysis completed that was forwarded to your staff on February 24, 2010, is technically adequate in calculating the risk associated with reduced inventory, NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding.
If you would like to discuss this further, please feel free to contact me.
Lois James, Chief PRA Operational Support (APOB)
Division of Risk Assessment (ORA)
Office of Nuclear Reactor Regulation (NRR) 301-415-3306 lois. james@nrc.gov 2
 
rov&cnJCn LV Franke, Mark From:
Franovich, Rani Sent:
Friday, June 04, 2010 9:01 AM To:
Lubinski, John Cc:
Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff; Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca


rov&cnJCn LV
==Subject:==
" Franke,
RE: St Lucie RCP seal weld SDP discussion Attachments:
- Franke, Mark Mark From:
Draft ROPFF for St Lucie Importance:
From:                         Franovich, Rani Franovich,  Rani Sent:
High Hey John, Good seeing you yesterday. As I mentioned at the All Supervisors Meeting, DIRS agrees with Region Ils significance characterization of the St. Lucie finding involving the RCP lower cavity seal line J-weld failure. We also agree with the sentiments you expressed below and recognize the need to examine governing guidance.
Sent:                         Friday, June Friday, June 04, 04, 2010   9:01 AM 2010 9:01 To:
We have initiated a feedback form to capture lessons learned and determine how and where that guidance can be clarified to ensure regional consistency/reliability.
To:                          Lubinski, John Lubinski, John Cc:
Paul forwarded the feedback form to Walt (see attached) for his review before I approve.., just wanted folks in HQ and Rll to be aware.
Cc:                          Rogers, Walt; Rogers,   Walt; Vargas,   Alexandra; Zoulis, Vargas, Alexandra;                        James, Lois; Zoulis, Antonios; James,         Laur, Steven; Lois; Laur, Steven; Ashley, Ashley, MaryAnn; Circle, MaryAnn;            Jeff; Franke, Circle, Jeff;  Franke, Mark;     Kennedy, Kriss; Mark; Kennedy,    Kriss; Christensen,           Sykes, Marvin; Harold; Sykes, Christensen, Harold;            Marvin; Leonard; Munday, Wert, Leonard; Wert,                               Cheok, Michael; Joel; Cheok, Munday, Joel;                        Cunningham, Mark; Michael; Cunningham,     Mark; Galloway,    Melanie; Nease, Galloway, Melanie;     Nease, Rebecca Rebecca
Im sure you enjoyed Atlanta and RIl; welcome back to HQ...
I Rani TC)r L(S From: Lubinski, John Sent: Friday, April 30, 2010 2:24 PM To: Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Cc: Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca


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


==Subject:==
==Subject:==
RE: St RE: St Lucie Lucie RCP RCP seal seal weld weld SDP SDP discussion discussion Attachments:
Attachments:
Attachments:                  Draft ROPFF Draft  ROPFF forfor St St Lucie Lucie Importance:
Importance:
Importance:                  High High Hey John, Hey  John, Good seeing Good    seeing you you yesterday. As II mentioned at      at the                     Meeting, DIRS Supervisors' Meeting, the All Supervisors                DIRS agrees            Region Ils agrees with Region       II's significance characterization significance    characterization of of the St.                     involving the RCP lower finding involving St. Lucie finding                            lower cavity seal seal line  J-weld failure.
Hey John, Franovich, Rani Friday, June 04, 2010 9:01 AM Lubinski, John Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff; Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca RE: St Lucie RCP seal weld SDP discussion Draft ROPFF for St Lucie High Good seeing you yesterday. As I mentioned at the All Supervisors' Meeting, DIRS agrees with Region II's significance characterization of the St. Lucie finding involving the RCP lower cavity seal line J-weld failure. We also agree with the sentiments you expressed below and recognize the need to examine governing guidance.
line J-weld   failure . We also agree with the sentiments also                                you expressed below sentiments you                    below and and recognize the need  need to examine      governing guidance.
We have initiated a feedback form to capture lessons learned and determine how and where that guidance can be clarified to ensure regional consistency/reliability. Paul forwarded the feedback form to Walt (see attached) for his review before I approve... just wanted folks in HQ and RII to be aware.
examine governing       guidance.
I'm sure you enjoyed Atlanta and RII; welcome back to HQ...
We have initiated aa feedback form form to capture                 learned and lessons learned capture lessons                                    how and determine how and and  where     that guidance guidance can be clarified to ensure              consistency/reliability. Paul ensure regional consistency/reliability.           Paul forwarded thethe feedback form to  to Walt (see (see attached) for his attached)        his review before II approve..,    just wanted folks approve ... just                          HQ and folks in HQ        RII to be aware.
Rani From: Lubinski, John Sent: Friday, April 30, 2010 2:24 PM To: Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Cc: Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Check, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca  
and Rll        aware.
I'm sure you enjoyed Atlanta and RII; Im                                    RIl; welcome back to HQ... HQ ...                                                ,    I Rani                                                                                                         TC)r            L(S John From: Lubinski, John Friday, April 30, 2010 2:24 PM Sent: Friday, Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; To: Franovich,                                                                            Lois; Laur, Steven; Ashley, MaryAnn; MaryAnn; Circle, Jeff Cc: Franke, Mark; Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok,        Check, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca


==Subject:==
==Subject:==
St Lucie RCP seal weld SDP discussion yesterday's conference call to discuss your perspectives on SOP My thanks to everyone for participating in yesterdays                                                                        SDP treatment for a potential St. Lucie RCP seal weld leak finding.
St Lucie RCP seal weld SDP discussion My thanks to everyone for participating in yesterday's conference call to discuss your perspectives on SOP treatment for a potential St. Lucie RCP seal weld leak finding.
After considering all views presented, and after additional discussion with Mark Franke, II believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licen's ee shutdown and entered reduced inventory operation. We did not identify performance deficiencies licensee associated with licensee shutdown operations or maintenance risk management as they affected repairs.
After considering all views presented, and after additional discussion with Mark Franke, I believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licen'see shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with licensee shutdown operations or maintenance risk management as they affected repairs.
The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's residents quarterly report.
The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's quarterly report.
In addition, our review of this finding clearly demonstrates that our SOP         SDP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's         licensees actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. II will talk with NRRlOIRS   NRRJDIRS about the next steps for such an examination.
In addition, our review of this finding clearly demonstrates that our SOP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. I will talk with NRRlOIRS about the next steps for such an examination.
11
1


Of. Franke, Mark Franke,    Mark From:
Franke, Mark From:
From:                          Lubinski, Lubinski, John John Sent:
Lubinski, John Sent:
Sent:                          Friday, Friday, April April 30,   2010 2:24 30, 2010    2:24 PM PM To:
Friday, April 30, 2010 2:24 PM To:
To:                            Franovich,   Rani; Rogers, Walt; Franovich, Rani;              Walt; Vargas,  Alexandra; Zoulis, Vargas, Alexandra;   Zoulis, Antonios; James, Lois; Antonios; James,  Lois; Laur, Laur, Steven; Steven; Ashley,                 Circle, Jeff MaryAnn; Circle, Ashley, MaryAnn;              Jeff Cc:
Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Cc:
Cc:                            Franke,         Kennedy, Kriss; Mark; Kennedy, Franke, Mark;                Kriss; Christensen, Christensen, Harold;           Marvin; Wert, Sykes, Marvin; Harold; Sykes,                  Leonard; Munday, Wert, Leonard;     Munday, Joel; Check, Joel;          Michael; Cunningham, Cheok, Michael;                     Mark; Galloway, Cunningham , Mark;                 Melanie; Nease, Galloway, Melanie;   Nease, Rebecca Rebecca
Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Check, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca


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


==Subject:==
==Subject:==
St Lucie St Lucie RCP     seal weld RCP seal          SOP discussion weld SDP    discussion My thanks My thanks to   everyone for to everyone  for participating in     yesterday's conference in yesterdays    conference call         discuss your to discuss call to                perspectives on your perspectives     on SDP SDP treatment for aa potential potential St.         Rep seal weld leak St. Lucie RCP                    leak finding.
Lubinski, John Friday, April 30, 2010 2:24 PM Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca St Lucie RCP seal weld SOP discussion My thanks to everyone for participating in yesterday's conference call to discuss your perspectives on SDP treatment for a potential St. Lucie Rep seal weld leak finding.
After considering After                    views presented, considering all views     presented, and after                   discussion with after additional discussion                  Franke, II believe Mark Franke, with Mark                            is consistent believe itit is our process with our   process to move move forward to to treat treat this       an At-Power finding. In as an this as                                other words, we In other              would not we would  not viewview this as aa finding warranting an as                          an Appendix Appendix G  G risk risk  assessment.     To To  perform   maintenance maintenance to  to correct the leak, the the leak, licensee shutdown licensee    shutdown andand entered                inventory operation.
After considering all views presented, and after additional discussion with Mark Franke, I believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with licensee shutdown operations or maintenance risk management as they affected repairs.
entered reduced inventory         operation. We We did did not           performance deficiencies identify performance not identify                deficiencies associated withwith licensee shutdown operations             maintenance risk management as they affected repairs.
The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's quarterly report.
operations or maintenance                                                      repairs.
In addition, our review of this finding clearly demonstrates that our SDP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensee's actions to fix the leak. In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward. I will talk with NRRlDIRS about the next steps for such an examination.
next steps The next                    action will be for Mark steps for this action                  Mark Franke to  to provide             input to DRP provide written input              Branch 33 for inclusion DRP Branch            inclusion inin next residents the next   resident's quarterly quarterly report.
1  
report.
demonstrates that our SDP procedures and processes need to be In addition, our review of this finding clearly demonstrates examined. As our guidance is currently written, aa number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on  on whether itit was appropriate to include risk associated                       licensee's actions to fix the associated with the licensees leak. In leak. In the interests of program reliability, we believe that NRR should      should examine whether changes are         are needed needed to clarify or change our policy going                                       NRRJDIRS about the next steps for such an going forward. II will talk with NRRlDIRS examination.
1


NRC FORM 757 NRC            757                                                    U.S. NUCLEAR REGULATORY COMMISSION COMMISSION NRC MD NRC      10.158 MD 10.158 (3-2009)
NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRC MD 10.158 (3-2009)
(3-2009)
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT ADAMS ACCESSION NO.
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT                                                                     I ADAMS ACCESSION NO. NO.
St. Lucie Inspection Report 05000389/2010003 SECTION D: CONTINUATION PAGE CONTINUATION OF SECTION B
St. Lucie Inspection Report 05000389/2010003 SECTION 0:   D: CONTINUATION CONTINUATION PAGE CONTINUATION OF      OF SECTION D   A D   B B
C NRC FORM 757 (3-2009)
D   C NRC FORM NRC  FORM 757 757 (3-2009)
Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRC MD 10.158 (3-2009)
(3-2009)                    Use ADAMS Template NRC-006 Use ADAMS          NRC-006                  PRINTED ON PRINTED ON RECYCLED RECYCLED PAPER PAPER}}
NON-CONCURRENCE PROCESS TITLE OF DOCUMENT I ADAMS ACCESSION NO.
St. Lucie Inspection Report 05000389/2010003 SECTION 0: CONTINUATION PAGE CONTINUATION OF SECTION D A D B D C NRC FORM 757 (3-2009)
Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER}}

Latest revision as of 03:50, 14 January 2025

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


Text

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

NON-CONCURRENCE PROCESS SECTION A - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL TITLE OF DOCUMENT ADAMS ACCESSION NO.

St. Lucie Inspection Reøort 05000389/2010003 DOCUMENT SPONSOR SPONSOR PHONE NO.

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

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

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Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD 10.158 (3*2009) u.s. NUCLEAR REGULATORY COMMISSION NON-CONCURRENCE PROCESS SECTION A - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL TITLE OF DOCUMENT St. Lucie Inspection Report 05000389/2010003 DOCUMENT SPONSOR Mark Franke NAME OF NON-CONCURRING INDIVIDUAL Walt Rogers D DOCUMENT AUTHOR D DOCUMENT CONTRIBUTOR TITLE Senior Reactor Analyst REASONS FOR NON-CONCURRENCE D DOCUMENT REVIEWER I

ORGANIZATION DRSlEB2 ADAMS ACCESSION NO.

SPONSOR PHONE NO.

404-997-4436 PHONE NO.

404-997-4619

~ ON CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance. The safety signficance of the performance deficiency are the consequences of the performance deficiency which includes the additional reduced inventory condition incured by the repair actiivties.

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NRC FORM 757 (3-2009)

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

NON-CONCURRENCE PROCESS TITLE OF DOCUMENT ADAMS ACCESSION NO.

St. Lucie Inspection Report 05000389/2010003 SECTION B - TO BE COMPLETED BY NON-CONCURRING INDMDUALS SUPERViSOR (THIS SECTION SHOULD ONLY BE COMPLETED IF SUPERVISOR IS DIFFERENT THAN DOCUMENT SPONSOR.)

NAME Rebecca L. Nease TITLE PHONE NO.

Chief, Engineering Branch 2 404-997-4530 ORGANIZATION Division of Reactor Safety, Region II COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER I HAVE NO COMMENTS I HAVE THE FOLLOWING COMMENTS I have reviewed the attached documentation, and it appears that all parties have acted in good faith, to consider all views with repsect to the subject of this non-concurrence. At issue is whether is is appropriate to use the shutdown operations significnce determination process (SDP) or the at-power SDP for the described performance deficiency. While a conclusion was reached that shutdown risk was not to be considered, it appears that this was not a consensus view among the staff in NRR and Region II. In addition, it appears that the guidance could have supported either view, depending on which part of the guidance was referenced. This ambiguity does not speak well for our principals of good regulation, especially the principal of clarity.

Having reviewed the documents attached herein, and read each view, either methodology (shutdown risk or at-power risk) appears to meet at least some parts of the guidance. However, in using shutdown risk to conclude a higher risk level, we would have had the opportunity (within the guidance) to send a strong message to the licensee that repeatedly entering a risk-signficant plant configuration to fix the same or similar degraded condition is not in the interest of safety.

I believe the confusing guidance bears revision to provide clarity to the process and to permit such latitide in egregious cases, such as this one.

CONTINUED IN SECTION D SIGNAT E

DATE 7/43//d SUBMIT THIS PAGE TO DOCUMENT SPONSOR NRC FORM 757 (3-2009)

Use ADAMS Template NRC.006 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD 10.158 (3-2009)

U.S. NUCLEAR REGULATORY COMMISSION NON-CONCURRENCE PROCESS TITLE OF DOCUMENT St. Lucie Inspection Report 0500038912010003 I ADAMS ACCESSION NO.

SECTION B - TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S SUPERVISOR (THIS SECTION SHOULD ONLY BE COMPLETED IF SUPERVISOR IS DIFFERENT THAN DOCUMENT SPONSOR.)

NAME Rebecca L. Nease TITLE Cbief, Engineering Brancb 2 ORGANIZATION Division of Reactor Safety. Region D COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER D I HAVE NO COMMENTS

!ill I HAVE THE FOLLOWING COMMENTS I

PHONE NO.

404-997-4530 I bave reviewed tbe attacbed documentation, and it appears tbat all parties bave acted in good faitb, to consider all views witb repsect to tbe subject of tbis non-concurrence. At issue is wbetber is is appropriate to use tbe sbutdown operations significnce determination process (SDP) or tbe at-power SDP for tbe described performance deficiency. While a conclusion was reacbed tbat sbutdown risk was not to be considered, it appears tbat tbis was not a consensus view among tbe staff in NRR and Region D. In addition, it appears tbat tbe guidance could bave supported eitber view, depending on wbicb part of tbe guidance was referenced. Tbis ambiguity does not speak well for our principals of good regulation, especially tbe principal of clarity.

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

D CONTINUED IN SECTION D SIGNAfLr1l/l Ii ~

v SUBMIT THIS PAGE TO DOCUMENT SPONSOR

". I I

NRC FORM 757 (3-2009)

Use ADAMS Template NRC-D06 PRINTED ON RECYCLED PAPER

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

NON-CONCURRENCE PROCESS TITLE OF DOCUMENT St Lucie Inspection Report 05000389/2010003 SECTION C

- TO BE COMPLETED BY DOCUMENT SPONSOR NAME Mark Franke ADAMS ACCESSION NO.

TITLE PHONE NO.

Branch Chief 404-997-4436 ORGANIZATION DRS/EB3 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised, as necessary, to reflect the final outcome of the non-concurrence process, including a complete discussion of how individual concerns were addressed.)

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

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

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

Additional meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, came to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance Assessment Branch, expressed concern over the whether it was programmatically appropriate and consistent to use Appendix G for this finding considering that the finding occurred At-power.

On April 30, 2010, after considering all of the perspectives, John Lubinski (acting DRS director) determined that it was consistent with our process and practice to process to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix C risk assessment. It would screen out per IMC 0609 Phase 1 screening. To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with the licensees shutdown operations or maintenance risk managment.

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

Rani Franovich, Chief of Performance Assessment, agreed with this decision via email on 6/4/201 0.

I have reviewed this non-concurrence documentation in detail. It illustrates the numerous important arguments and counter-arguments that the staff discussed and highlights several areas for potential SDP guidance clarification. Because I believe that these arguments were thoughtfully considered in the April 30 decision, I do not propose reversing that decision.

The performance deficiency was not viewed to extend into the licensees decisions to shutdown and repair. To address staff division and concerns over this, DIRS initiated an effort to examine whether changes were needed in NRC procedures to ensure clarity, reliability, and efficiency going forward. DIRS initiated an ROP feedback form to track this effort.

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

This path also provides for additional stakeholder participation and communication should SDP guidance revisions occur.

/

NON-CONCURS WITHDRAWS NON-CONCURRENCE (i.e., discontinues process)

CONTINUED IN SECTION D DAT

/WANTS NCP FORM PUBLIC WANTS NCP FORM NON-PUBLIC CONCURS process is complete, i.e., after document is signed):

NRC FORM 757 (3-2009)

Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD10.158 (3-2009)

TITLE OF DOCUMENT NON~ONCURRENCEPROCESS U.S. NUCLEAR REGULATORY COMMISSION IADAMS ACCESSION NO.

8t Lucie Inspection Report 05000389/2010003

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

SECTION C - TO BE COMPLETED BY DOCUMENT SPONSOR NAME Mark Franke TITLE Branch Chief ORGANIZATION DRSlEB3 I

PHONE NO.

404-997-4436 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised, as necessary, to reflect the final outcome of the non-concurrence process, including a complete discussion of how individual concerns were addressed.)

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

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

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

Additional meetings and conference calls were held with Region, NRR PRA and DIRS staff to discuss all views and perpectives. It became evident that a number of experienced staff, working with the same facts and using current guidance, came to substantially different conclusions on the SDP treatment of this finding. Rani Franovich, Chief of Performance Assessment Branch, expressed concern over the whether it was programmatically appropriate and consistent to use Appendix G for this finding considering that the finding occurred At-power.

On April 30, 2010, after considering all of the perspectives, John Lubinski (acting DRS director) determined that it was consistent with our process and practice to process to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment. It would screen out per IMC 0609 Phase 1 screening. To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with the licensee's shutdown operations or maintenance risk managment.

(Reference Lubinski email 4/30110, attached). Rani Franovich,Chief of Performance Assessment, agreed with this decision via email on 6/4/2010.

I have reviewed this non-concurrence documentation in detail. It illustrates the numerous important arguments and counter-arguments that the staff discussed and highlights several areas for potential SDP guidance clarification. Because I believe that these arguments were thoughtfully considered in the April 30 decision, I do not propose reversing that decision.

The performance deficiency was not viewed to extend into the licensee's decisions to shutdown and repair. To address staff division and concerns over this, DIRS initiated an effort to examine whether changes were needed in NRC procedures to ensure clarity, reliability, and efficiency going forward. DIRS initiated an ROP feedback form to track this effort.

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

This path also provides for additional stakeholder participation and communication should SDP guidance revisions occur.

D CONTINUED IN SECTION D tsSTGi II~

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D CONCURS o NON-CONCURS D W ITHDRAWS NON-CONCURRENCE (Le., discontinues process)

NRC FORM 757 (3-2009)

Use ADAMS Template NRC-D06 c6 WANTS NCP FORM PUBLIC D WANTS NCP FORM NON-PUBLIC PRINTED ON RECYCLED PAPER

Lo -LQA Franke, Mark From:

Nease, Rebecca Sent:

Friday, March 05, 2010 2:34 PM To:

Franke, Mark; Vargas, Alexandra

Subject:

FW: SDP Phase 3 Analysis Of St. Lucie RCP Seal Leak-Off Line Leak NRRs basis for not using App G.

From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie

Subject:

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

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

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

During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place. Clearly, the performance deficiency caused a TS require unit shutdown, however, the performance deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRR/DRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding.

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

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

o For deficiencies occurring above the RHR entry conditions, the full power SDP tools should be used...[section 2.1]

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

IMC 0609 Attachment 4 provides guidance that performance deficiencies during shutdown modes to be evaluated using Appendix G:

o IF the finding affects: the safety of a reactor during refueling outages, forced outages, and maintenance outages starting, when the licensee has met the entry conditions for RHR and RHR cooling has been initiated, THEN STOP. Go to IMC 0609, Appendix G.

The RASP Handbook provides a specific exception when repair time should not be included in the exposure time to deal with this type of finding:

o If the plant is shutdown and the deficiency only affects an at-power condition, then repair time should not be included 1

Franke, Mark From:

Sent:

To:

Subject:

Nease, Rebecca Friday, March 05, 20102:34 PM Franke, Mark; Vargas, Alexandra FW: SDP Phase 3 Analysis Of St. Lucie Rep Seal Leak-Off Line Leak NRR's basis for not using App G.

From: James, Lois Sent: Wednesday, March 03, 2010 6:00 PM To: Nease, Rebecca Cc: Cunningham, Mark; Galloway, Melanie

Subject:

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

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

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

During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place. Clearly, the performance deficiency caused a TS require unit shutdown, however, the performance deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant. Therefore, NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding.

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

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

o For deficiencies occurring above the RHR entry conditions, the full power SDP tools should be used... [section 2.1]

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

IMC 0609 Attachment 4 provides guidance that performance deficiencies during shutdown modes to be evaluated using Appendix G:

o IF the finding affects: the safety of a reactor during refueling outages, forced outages, and maintenance outages starting, when the licensee has met the entry conditions for RHR and RHR cooling has been initiated, THEN STOP. Go to IMC 0609, Appendix G.

The RASP Handbook provides a specific exception when repair time should not be included in the exposure time to deal with this type of finding:

o If the plant is shutdown and the deficiency only affects an at-power condition, then repair time should not be included 1

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

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

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

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

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

Lois James, Chief PRA Operational Support (APOB)

Division of Risk Assessment (DRA)

Office of Nuclear Reactor Regulation (NRR) 301-41 5-3306 lois. james(nrc.qov 2

Further. NRRlDRA performed a quick search of findings on the Dynamic Webs Page to identify findings that were found at-power and included risk insights from IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. No findings were identified that applied IMC 0609 Appendix G to an at-power finding.

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

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

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

Lois James, Chief PRA Operational Support (APOB)

Division of Risk Assessment (ORA)

Office of Nuclear Reactor Regulation (NRR) 301-415-3306 lois. james@nrc.gov 2

rov&cnJCn LV Franke, Mark From:

Franovich, Rani Sent:

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

Lubinski, John Cc:

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

Subject:

RE: St Lucie RCP seal weld SDP discussion Attachments:

Draft ROPFF for St Lucie Importance:

High Hey John, Good seeing you yesterday. As I mentioned at the All Supervisors Meeting, DIRS agrees with Region Ils significance characterization of the St. Lucie finding involving the RCP lower cavity seal line J-weld failure. We also agree with the sentiments you expressed below and recognize the need to examine governing guidance.

We have initiated a feedback form to capture lessons learned and determine how and where that guidance can be clarified to ensure regional consistency/reliability.

Paul forwarded the feedback form to Walt (see attached) for his review before I approve.., just wanted folks in HQ and Rll to be aware.

Im sure you enjoyed Atlanta and RIl; welcome back to HQ...

I Rani TC)r L(S From: Lubinski, John Sent: Friday, April 30, 2010 2:24 PM To: Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Cc: Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca

Subject:

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

After considering all views presented, and after additional discussion with Mark Franke, I believe it is consistent with our process to move forward to treat this as an At-Power finding.

In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with licensee shutdown operations or maintenance risk management as they affected repairs.

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

In addition, our review of this finding clearly demonstrates that our SDP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensees actions to fix the leak.

In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward.

I will talk with NRRJDIRS about the next steps for such an examination.

1

" Franke, Mark From:

Sent:

To:

Cc:

Subject:

Attachments:

Importance:

Hey John, Franovich, Rani Friday, June 04, 2010 9:01 AM Lubinski, John Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff; Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca RE: St Lucie RCP seal weld SDP discussion Draft ROPFF for St Lucie High Good seeing you yesterday. As I mentioned at the All Supervisors' Meeting, DIRS agrees with Region II's significance characterization of the St. Lucie finding involving the RCP lower cavity seal line J-weld failure. We also agree with the sentiments you expressed below and recognize the need to examine governing guidance.

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

I'm sure you enjoyed Atlanta and RII; welcome back to HQ...

Rani From: Lubinski, John Sent: Friday, April 30, 2010 2:24 PM To: Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Cc: Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Check, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca

Subject:

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

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

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

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

1

Franke, Mark From:

Lubinski, John Sent:

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

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

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

Subject:

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

After considering all views presented, and after additional discussion with Mark Franke, I believe it is consistent with our process to move forward to treat this as an At-Power finding.

In other words, we would not view this as a finding warranting an Appendix G risk assessment. To perform maintenance to correct the leak, the licensee shutdown and entered reduced inventory operation. We did not identify performance deficiencies associated with licensee shutdown operations or maintenance risk management as they affected repairs.

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

In addition, our review of this finding clearly demonstrates that our SDP procedures and processes need to be examined. As our guidance is currently written, a number of experienced staff, working with the same facts, came to substantially different conclusions on the appropriateness of the process used. Specifically, there was disagreement on whether it was appropriate to include risk associated with the licensees actions to fix the leak.

In the interests of program reliability, we believe that NRR should examine whether changes are needed to clarify or change our policy going forward.

I will talk with NRRJDIRS about the next steps for such an examination.

Of Franke, Mark From:

Sent:

To:

Cc:

Subject:

Lubinski, John Friday, April 30, 2010 2:24 PM Franovich, Rani; Rogers, Walt; Vargas, Alexandra; Zoulis, Antonios; James, Lois; Laur, Steven; Ashley, MaryAnn; Circle, Jeff Franke, Mark; Kennedy, Kriss; Christensen, Harold; Sykes, Marvin; Wert, Leonard; Munday, Joel; Cheok, Michael; Cunningham, Mark; Galloway, Melanie; Nease, Rebecca St Lucie RCP seal weld SOP discussion My thanks to everyone for participating in yesterday's conference call to discuss your perspectives on SDP treatment for a potential St. Lucie Rep seal weld leak finding.

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

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

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

1

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

NON-CONCURRENCE PROCESS TITLE OF DOCUMENT ADAMS ACCESSION NO.

St. Lucie Inspection Report 05000389/2010003 SECTION D: CONTINUATION PAGE CONTINUATION OF SECTION B

C NRC FORM 757 (3-2009)

Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRC MD 10.158 (3-2009)

NON-CONCURRENCE PROCESS TITLE OF DOCUMENT I ADAMS ACCESSION NO.

St. Lucie Inspection Report 05000389/2010003 SECTION 0: CONTINUATION PAGE CONTINUATION OF SECTION D A D B D C NRC FORM 757 (3-2009)

Use ADAMS Template NRC-006 PRINTED ON RECYCLED PAPER

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