ML102100007

NRC Integrated Inspection Report 2010003 - Non-Concurrence (Public)

ML102100007
Person / Time
Site:	Saint Lucie
Issue date:	06/28/2010
From:	Franke M E NRC/RGN-II/DRS/EB3
To:
References
IR-01-003
Download: ML102100007 (8)

Text

NRC FORM 757 NRC MD 10.158 (3*2009) u.s. NUCLEAR REGULATORY COMMISSION NON-CONCURRENCE PROCESS SECTION A -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL TITLE OF DOCUMENT St. Lucie Inspection Report 05000389/2010003 DOCUMENT SPONSOR Mark Franke NAME OF NON-CONCURRING I NDIVIDUAL Walt Rogers D DOCUMENT AUTHOR D DOCUMENT CONTRIBUTOR TITLE Senior Reactor Analyst REASONS FOR NON-CONCURRENCE D DOCUMENT REVIEWER I ORGANIZATION DRSlEB2 ADAMS ACCESSION NO. SPONSOR PHONE NO. 404-997-4436 PHONE NO. 404-997-4619 ON CONCURRENCE As discussed in detail in the attached document, the performance deficiency associated with inadequate licensee engineering causing a Reactor Coolant Pump failed seal line weld is being improperly classified as to safety significance.

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\.A\+h D CONTINUED IN SECTION D SIGNATURE .. L r SUBMIT FORM TO DOCUMENT SPONSOR AND eOPY TO YOUR IMMEDIATE SUPERVISOR AND DIFFERING VIEWS PROGRAM MANAGER .' NRC FORM 757 (3-2009) Use ADAMS Template NRc'()06 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD 10.158 (3-2009) U.S. NUCLEAR REGULATORY COMMISSION NON-CONCURRENCE PROCESS TITLE OF DOCUMENT St. Lucie Inspection Report 0500038912010003 I ADAMS ACCESSION NO. SECTION B -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S SUPERVISOR (THIS SECTION SHOULD ONLY BE COMPLETED IF SUPERVISOR IS DIFFERENT THAN DOCUMENT SPONSOR.)

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 NR C M D10.158 (3-2009) TITLE OF DOCUMENT U.S. NUCLEAR REGULATORY COMMISSION I ADAMS ACCESSION NO. 8t Lucie Inspection Report 05000389/2010003 SECTION C -TO BE COMPLETED BY DOCUMENT SPONSOR NAME Mark Franke TITLE Branch Chief ORGANIZATION DRSlEB3 --------------------

I PHONE NO. 404-997-4436 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised , as necessary, to reflect the final outcome of the non-concurrence process, i ncluding a complete d i scussion of how individual concerns were addressed.) The issue at the heart of this non-concurrence is whether it is appropriate to assess shutdown risk (use IMC 0609 Appendix G) for the attached RCP 2B2 failed seal line finding. I believe that all parties have made a good faith effort over the last several months to gather and discuss all perspectives related to the SDP treatment of this finding. The parties in discussion included, but were not limited to, Region 2 DRS and DRP, and NRR DIRS and DRA. On March 3,2010, after a review, Lois James, Chief of PRA Operational Support concluded that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should not be used to evaluate this finding and stated that NRRlDRA did not believe this performance deficiency affected operations during shutdown conditions.

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 1';;Zb (;0 NON-CONCURRING INDIVIDUAL (To be completed by documerl sponsor when process is complete , i.e., after document is signed): D CONCURS o NON-CONCURS D W I THDRAWS NON-CONCURRENCE (L e., d i scontinues process) NRC FORM 757 (3-2009) Use ADAMS Template NRC-D06 c6 WANTS NCP FORM PUBLIC D WANTS NCP FORM NON-PUBLIC PRINTED ON RECYCLED PAPER Franke, Mark From: Sent: To:

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 Determinat i on Process (SDP) analysis to estimate the risk significance of a performance deficiency causing a Technical Specification (TS) requ i red unit shutdown and entry into an unplanned reduced inventory at St. Lucie Unit 2 during the month of July 2009. The performance def i ciency was a failure to correct and prevent the recurrence of RCS pressure boundary leakage through the Reactor Coolant Pump (RCP) seal line J-weld. APOS staff forwarded the Phase 3 SDP to Region II staff on February 24, 2010. During the peer review of this Phase 3 SDP analysis, questions were raised regarding the appropriateness of considering the risk incurred during reduced inventory where the repair of the RCS seal leak-off line took place. Clearly, the performance deficiency caused a TS require unit shutdown, however, the performance deficiency, in and of itself, did not cause the shutdown, including the reduced inventory, to be more risk significant.

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

In conclusion, while the PRA analysis completed that was forwarded to your staff on February 24 , 2010, is technically adequate in calculating the risk associated with reduced inventory, NRRlDRA does not believe that IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, should be used to evaluate this finding. If you would like to discuss this further, please feel free to contact me. Lois James , Chief PRA Operational Support (APOB) Divis i on of R i sk Assessment (ORA) Office of Nuclear Reactor Regulation (NRR) 30 1-415-3306 lois. james@nrc.gov 2

" Franke, Mark From: Sent: To: Cc:

Subject:

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

Subject:

St Lucie RCP seal weld SDP discussion My thanks to everyone for participating in yesterday's conference call to discuss your perspectives on SOP treatment for a potential St. Lucie RCP seal weld leak finding. After considering all views presented, and after additional discussion with Mark Franke, I believe it is consistent with our process to move forward to treat this as an At-Power finding. In other words, we would not view this as a finding warranting an Appendix G risk assessment.

To perform maintenance to correct the leak, the licen'see shutdown and entered reduced inventory operation.

We did not identify performance deficiencies associated with licensee shutdown operations or maintenance risk management as they affected repairs. The next steps for this action will be for Mark Franke to provide written input to DRP Branch 3 for inclusion in the next resident's quarterly report. In addition, our review of this finding clearly demonstrates that our SOP procedures and processes need to be examined.

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

1 Of Franke, Mark From: Sent: To: Cc:

Subject:

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 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