ML19219A076

OGC Released Set_NRC-2017-000292 (Interim 2)

ML19219A076
Person / Time
Issue date:	08/02/2019
From:	NRC/OCIO
To:
Shared Package
ML19219A087	List: ML19219A067 ML19219A068 ML19219A069 ML19219A070 ML19219A072 ML19219A073 ML19219A074 ML19219A076 ML19219A077 ML19219A079
References
FOIA, NRC-2017-000292
Download: ML19219A076 (93)

Text

From: Sent: To:

Subject:

Spencer , M ic hael Thursday. J u ne 23. 2016 11: 18 AM Scarbrough , Thomas; Holahan. Gary; West, Steven; Clark, Theresa RE: Back fit Appeal Panel I am available any time thi s afternoon (including 3 PM) and Monday at 3 PM. From: Scarbrough, Th omas Sent: Thursday, June 23 , 2016 11:11 AM To: Holahan, Gary <Gary.Holahan@nrc

.gov>; Spencer , Michael <Michael.Spencer@nrc.gov>;

West, Steven ; Clark, Theresa <Theresa.C l ark@nrc.gov>

Subject:

RE: Backfit Appeal Panel I am available today at 3 pm , but I am not availab l e Monday afternoon. Thanks. Tom From: Holahan, Gary Sent: Thursday , June 23, 2016 11:01 AM To: Spencer, Michael <Michael.Spencer@nrc.gov>;

West, Steven <~teve11.Wesl@!!.rc.gov>;

Scarbrough, Thomas ;

Clark , Th eresa <!'heres a.Clark@n r c.gov>

Subject:

RE: Backfit Appeal Panel Does 2pm or 3pm Monday work better for panel membe r s? I can be available for either. Gary From: Spencer, Michael Sent: Thursday, June 23, 2016 1 0: 59 AM To: Holahan, Gary <Garv.H o l ahan@nrc.gov>

Subject:

RE: Backfit Appeal Panel Gary , I have a conflict.

I have been asked t o attend another meet i ng on Monday from 1 to 2: 30. Is another time available on Monday? Michael -----Original Appointment

---** From: H olahan, Gary Sent: Thursday, June 23, 2016 10:57 AM To: West, Steven; Spencer, Michael; Scarbrough, Thomas; Clark, Theresa

Subject:

Backfit Appeal Panel When: Monday, June 27, 20161:00 PM-2:00 PM (UTC-05:00)

Eastern Time (US & Canada). Where: O 17 H 14 2

Subject:

Location:

Start: End: Recurrence

Meeting Status: Organizer: Required Attendees:

Backfit Appeal Pane l 0 17 H 14 Thu 06/23/2016 3: 00 PM Thu 06/23/2016 4: 00 PM (none) Accepted Holahan , Gary West , S te v e n; S p encer , M i chael; Scarbrough , Thomas; Clark, Theresa From: Sent: To:

Subject:

HO L AHAN , GA RY M Frida y , June 24. 2016 11: 11 AM CLARK , THERE SA V; WEST , Steven S; SCARBROUG H, T HOMAS G; SPENCER, MICHAEL A Re: back fi t appea l pane l Thanks Theresa, I need to he out of the office 7/7 and 7/8 so o n e meeting the week of July 4 is Ok. Gary On: 24 June 2016 11 :04 , "CLARK , THERESA V <The r esa.C lark@nr c.gov> wrote: Not e that Tom is !<b)(6) !but others appear to b e OK for th is one. [FYI didn't s chedul e for 7/7 as th e r e wa s n't a good tim e for all.I

Subject:

Location:

Start: End: Recurrence

Meeting Status: Organizer:

Required Attendees: Ba c kfi t Pane l Meet i ng 017 H 14 Tue 06/28/2016 3: 00 P M Tue 06/2 8/20 1 6 4: 00 P M (n one) Acc epte d Ho l ahan , Ga ry West , St e v en; S c a rbr ough , Thomas; Sp en c e r , Michael; Clark, Theresa

Subject:

location: Start: End: R ec urr e nc e: Meeting Status: Organizer:

Required Attendees: backfit appea l pa n e l 0-16B2 Thu 06/30/2016 1 0: 00 AM Thu 06/30/20 1 6 1 1:00 AM (none) Accepted CLARK , THERESA V HOLAHAN , GARY M; WEST , Steven S; SCARBR OUGH, THOMAS G; SPENCER, MICHAE L A This t ime looked OK if Steve can get out of hi s stand i ng meet ing. P l ea s e note thal the room labeling is messed up right no w , but I h ave 0-1602 re ser ved (I think) as not e d in the s ubject l i ne. Thanks, Th eresa From: Sent: To:

Subject:

OK with me. Thanks. Tom From: Holahan , Gary Scarbrough , T h om as Thursda y, J u ly 0 7 , 2016 9:57 AM Ho l a ha n, Gary; West. Steven; Clark , Theresa; Spencer , Michael R E: Memorandum Fr om: V. M cCree to G. Holahan re: Charter for Ba ck fit Ap pea l Review Pane l Associated wi th Byron and Braidwood Compliance with 10 CFR 50.34(8), GDC 15 , GDC 21 , GDC 29 , and the Licensi ng Basis Sent: Thursday, July 07 , 2016 9: 55 AM To: West, S t eve n <Steven.Wes t@nrc.g ov>; C lark , Theresa <The resa.Clark@nrc.gov>; Scarb r o ugh , Th omas ;

Spencer , Mi ch ael <Mic hae l.Sp e nce r@nrc.gov>

Subject; Fwd: Memorandum Fro m: V. Mcc re e to G. H o l ahan re: Ch a r ter for Backfit Appeal Review Panel Associated with Byron and Braidwood Com plian ce wit h 10 C FR 50.34(6), GDC 15, GDC 2 1 , GDC 29, and t he Licensing Basis How abo ut inviting Ri ch t o a pan e l me e t ing n ex t wee k? Gary From: "West , Steven" <Stevcn.West@nrc.gov

>

Subject:

RE: Memorandum From: V. McCree to G. Holahan re; Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Co mpli a n ce with 10 CF R 50.34(8), G D C 15. GDC 21 , GDC 29, and the L i censing Ba sis Date: 07 July 2016 09: 12 To: "Correia, Ri chard" <Richard.Corrcia(d ,nrc.gov> Cc: "H o l ahan, Gary" <Gary.H ola h a n C<"Z: nr c.gov> The appeal panel is still in the discove r y p h ase. It's h ighl y like ly that we'll a sk for RES assi s tance as summarized in my origina l em ail , be l ow , bu t we are not qu it e ready yet. Steve Steven We s t , Deputy Dire cto r Office of Nuclear Security a nd Inciden t Respo n se U.S. Nu c l ea r Regulatory Co m m i ssion 301-28 7-3734 Steven.West@nrcgov From: Correia, Richard Sent: Thursday, July 07, 2016 7:07 AM To: West, Steven <Steven.West@nrc.gov>

Subject:

RE: Memorandum From: V. McCree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(8), GDC 15, GDC 21, GDC 29, and the Licensing Basis Good morning Steve. Any updates on this appeal and whether you still want our technical assistance?

Best Richard P. Correia, P.r .. Diredor, Oivisio11 o! Risk Analysis Office of l\iuclcar Reenlatory Research U.S. '.'IRC From: Correia, Richard Sent: Friday, June 24, 2016 6:38 AM To: West, Steven <Steven.West@nrc.gov>

Cc: Weber, Michael <Michael.Weber@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

Case, Michael <Michael.Case@nrc.gov>;

Webber, Kimberly <Kimberly.Webber@nrc.gov>;

Thaggard, Mark <Mark.Thaggard@nrc.gov>;

Hackett, Edwin <Edwin.Hackett@nrc.gov>

Subject:

RE: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(8), GOC 15, GOC 21, GDC 29, and the Licensing Basis Steve, We will be ready to support your request and look forward to working with you and Gary on this matter. Best Richard P. Correia, P.E. Director, Division of Risk AnahJsis OHico al :"J°udear Roaula tonJ Research U.S.NRC From: West, Steven Sent: Thursday, June 23, 2016 6:13 PM To: Correia, Richard <Richard.Correia@nrc.gov>

Cc: Weber, Michael <Michael.Weber@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

Case, Michael <Michael.Case@nrc.gov>;

Webber, Kimberly <Kimberly.Webber@nrc.gov>;

Thaggard, Mark <Mark.Thaggard@nrc.gov>

2

Subject:

FW: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(0), GDC 15, GDC 21, GDC 29, and the Licensing Basis Rich, Following (and attached) is the information on the backfit appeal I am working on. I appreciate your commitment to support the panel's effort to better understand and characterize the safety and risk significance of the plant configuration.

Gary Holahan or I will be in touch after we gather our thoughts and have a better idea about specific objectives and needs. As I mentioned to you. we will probably be looking for some transient analyses and risk assessments (using SPAR models). Steve Steven West. Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven. West@nrc.gov From: Holahan, Gary Sent: Thursday, June 23, 2016 10:44 AM To: West, Steven <5teven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>

Cc: Clark, Theresa <Theresa.Clark@nrc.gov>

Subject:

FW: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(8), GDC 15, GDC 21. GDC 29, and the Licensing Basis Steve, Tom, Michael, As you can see, the EDO has signed the Backfit Appeal Panel Charter. It calls for a final report and recommendation by August 29. 2016. Although t do not expect this task to require anyone's dedicated. time attention, I do plan to meet frequently, especially during the planning stage. I suggest meeting this afternoon (3 pm?) or on Monday and Wednesday next week. I suggest that we establishing a regular pattern of meetings for the following weeks. There will also be the need to schedule meetings/discussions with NRR staff and management, Exelon. perhaps NEI (which sent a supporting letter last week). other stakeholders.

and perhaps CRGR. I have identified more than 20 relevant documents (electronic copies of a few attached, including a list of all); and I am having paper copies made. Copies should be available on Monday. The most immediately relevant documents are: the charter, the Exelon appeal letters of 12/8/15 (to NRR) and 6/2/16 (to EDO), and the staff letter of 5/3/16. I have identified numerous issues that I think we may need to pursue, but that can wait for our first meeting. I will send scheduler requests to check your availability today and next week. Thanks in advance for your support, Gary 3 From: Royer, Deanna Sent: Thursday, June 23, 2016 10:01 AM To: Holahan, Gary <Gary.Holahan@n rc.gov>; West, Steven <Steven.West@nrc.gov>;

Sca rbrough, Thomas <Thomas.Scarbrough@nrc

.gov>; Spencer , Michael <Michael.Spencer@nrc.gov>

Cc: AidsNroMailCenter Resource <RidsNroMailCenter

.Resource@nrc.gov>;

RidsNrrOd Resource < RidsN rrOd.Resource@nrc.gov>;

RidsRgn3 Ma ilCe nter Resource <RidsRgn3Ma ilCenter.Resource@nrc.gov>;

RidsOgcMailCenter Resource <RidsOgcMailCenter

.Re source@nrc.gov>;

RidsEdoMailCenter R esource <RidsEdoMailCenter.Resource@nrc.gov>;

Clark , Theresa <Theresa.Clark@nrc.gov>

Subject:

Memorandum from: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR S0.34(B), GDC 15 , GDC 21. GDC 29, and the Licensing Basis Dated: J unc 22, 2016 From: V. \1cCrec View ADA\lfS P8 J>ropt=rties MLI 6 I 73A3 I! P ublicly A v a il ab l e i n ADAMS Open ADA\lfS P8 Docui:ncnt (Charter for B acklit Appeal R e view P,~ncl A s s o ciated With Byron and Braidwood Compl_ian_<;:c with 10_ C FR 50.34<8}, GDC 15, GD(.21., GDC 29 , and the Liccn_sin g Basis) Thank s, Deanna Royl!r Administrative

/\ssi s tanl lo Fred M:illcr, Al!ting Dirl!.;t or Samuel I.cc, Acting Deputy Dirc-.:t o r Divi s ion of Program M:anu~cmcnt.

Pohl!)' Development and Analysis (301)415-1207 T-06/1-" 11 Mailstop:

T-06/Fl 5 4 From: Sent: To:

Subject:

Thank s, Steve and There sa Holahan , Gary Thursday , Ju l y 07 , 2016 12: 40 PM Clark. Theresa; West. Steven; Scarbrough , Th omas; Spencer , Michael Re: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Ass ocia ted with Byron and Braidwood Compliance with 10 CFR 50.34(9), GDC 15, GDC 21. GDC 29. and the Licensin g Bas i s On: 07 July 2016 l 0: 19. "Clark. Ther esa" <Ther esa.Clark (!."i J nrc.gov> wrote: I'll add him to the appointment later today. Th a nks! On: 07 July20l6 l0:1 8, "West. Steve n" <Steven.West (£i n rc.gm*> wrote: Gary , I am on travel next week. but suggest you invit e Rich. even i f it is for a preliminary discussion about what the panel is dealing with and the type and level of support we might need to complete our review. This would allow Rich to develop a feel for the RES resources and time needed. Also , our request to RES may also require coordination with/assistance for Mike Case*s division. Rich can help with this as well. Steve Steven West, Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven.West@nrc

.gov From: H o lahan, Gary Sent: Thursday , July 07, 2016 9:55 AM To: West. Steven <Steven.West@nrc.gov>;

Clark , Theresa <Theresa.Cla rk@nr c.gov>; Scarbrough, Thomas <Thomas.Scarbrough@nr c.gov>; Spencer, Michael <Michael.S pence r@nrc.gov>

Subject:

Fwd: Memorandum From: V. M ccree t o G. Hola han re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(9), GOC 15 , GOC 21, GOC 29, and the Licensing Basis How about inviting Rich to a panel meeting next week'? Gary From: "West, Steven" <Stevcn.West@nrc.gov>

Subject:

RE: Memorandum From: V. McCrce to G. Holahan re: Charter for Back fit Appeal Review Panel Associated with Byron and Braidwood Compliance with IO CFR S0.34(B), GDC 15, GDC 21, GDC 29, and the Licensing Basis Date: 07 July 2016 09: 12 To: "Correia.

Richard

<Richard.Correia(c, .. nrc.gov> Cc: "Holahan, Gary" <Gary.Holahan(t'l'nrc.gov>

The appeal panel is still in the discovery phase. It's highly likely that we'll ask for RES assistance as summarized in my original email, below. but we are not quite ready yet. Steve Steven West. Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven.West@nrc.gov From: Correia, Richard Sent: Thursday, July 07, 2016 7:07 AM To: West, Steven <Steven.West@nrc.gov>

Subject:

RE: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(B), GDC 15, GDC 21, GDC 29, and the Licensing Basis Good morning Steve, Any updates on this appeal and whether you still want our technical assistance?

Best Richard P. Correia, P.E.. Director, Division oi Risk Analqsis OHiceol Nuclear Resulatory Research U.S.NRC From: Correia, Richard Sent: Friday, June 24, 2016 6:38 AM To: West, Steven <Steven.West@nrc.gov>

Cc: Weber, Michael <Michael.Weber@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

Case, Michael <Michael.Case@nrc.gov>;

Webber, Kimberly <Kimberly.Webber@nrc.gov>;

Thaggard, Mark <Mark.Thaggard@nrc.gov>;

Hackett, Edwin <Edwin.Hackett@nrc.gov>

Subject:

RE: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(0), GDC 15, GDC 21, GDC 29, and the Licensing Basis 2 Steve, Tom, Michael, As you can see. the EDO has signed the Backfit Appea l Panel Ch arter. It calls for a final report and re co mmend a tion by Augu st 29 , 2016. A lt hough I d o not expect this task to require anyone*s dedicated , time attention , l do plan to meet fre que n tly , espec ia lly du ri ng the planning stage. I suggest meeting this afternoon (3 pm?) or on M ond ay and Wednesday next week. I s ugges t that we establishing a regular pattern of meetings for the following weeks. There will also be the need to schedule meetings/discussions with NRR staff and managemen1, Exe l on , perhaps NEI (which sent a support i ng letter last week), other stakeholders, and perhaps CRGR. I have identified more than 20 re l e van t d o c umen ts {e l ectronic c o pi es of a few attached , including a list of all): and I am having paper copies m ade. Cop i es shou l d b e ava il ab l e on M onday. The most imm edi ately relevant docum ents a re: the charter, the Exelon appeal letters o f 12/8/15 (to NRR) an d 6/2/16 (to EDO), and the sta ff letter of 5/3/16. I have identified nu m erous issues t ha t I th ink we may need to pursue, but that can wait for our fir st m eeti ng. I will send scheduler requests t o check yo u r availab il ity tod a y and next week. Thanks in advance for your support. Gary From: Roye r, Deann a Sent: Thursday , June 23 , 2016 10:01 AM To: Holahan, Gary <Gary.Holahan@nrc.gov

>; West , Steven ; Scarbrough, Thoma s <Thoma s.Scarbrough@nr c.gov>; S pen c er, Michael <Michae l.S penc e r@nrc.gov>

Cc: RidsNroMailCenter Resource <RidsNroMai lC e nt er.R esource@n r c.gov>; RidsNrrOd Resource <RidsNrrOd

.Re so urce@nrc.go v>; RidsRgn3Mai1Cente r Resource <R i d sR gn 3 Mai1Center.Reso urce@nrc.gov

>; RidsOg c MailC en t e r Re so urce <R i dsOgcM a i1Center.Re s o urce@n rc.gov>; R idsEdoMail C e nt er Re so ur ce <RidsEdoMailCenter

.Resource@nrc.go v>; Clark. There sa <Theresa.C l ark@nrc.gov>

Subject:

Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 C FR 50.34(8), G DC 15, GDC 21 , GDC 29 , and the Licensing Basi s Dated: June 22. 2016 From: V. Mccree E Available i n ADAMS View AQA\1S P8 Propertie s MU 6 I 73A3 I I Qpc n ADA\1S J>8 Document (Ch.i rter for Ba c k fit Appeal Re v iew P~mcl Assodatt:d

_Wi t.h Byron and Braidwood Compliance

_with 1 0 C FR 50.34(8). GDC 15. GDC 21, Gl)C ;!.9. and the Licensi.ng Ba s is) Th anks. D e ann.i Royer Adm ini s t rn ti ve A ss i s tant t o Fred Miller. Acting Director Sam uel Lee, Acting Deputy Di r e c t or Divisi o n of Pr og r am M a n ag ement. Policy D e velopm e nt and A nalysis 4 Steve, We will be ready to support your request and look forward to working with you and Gary on this matter. Best Richard P. Correia, P.E Director, Division al Risk Ana.hJsis OHice 0£ Nuclear RegulatonJ Research U.S.NRC From: West, Steven Sent: Thursday, June 23, 2016 6:13 PM To: Correia, Richard <Richard.Correia@nrc.gov>

Cc: Weber, Michael <Michael.Weber@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

Case, Michael <Michael.Case@nrc.gov>;

Webber, Kimberly <Kimberly.Webber@nrc.gov>;

Thaggard, Mark <Mark.Thaggard@nrc.gov>

Subject:

FW: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(8), GOC 15, GOC 21, GDC 29, and the licensing Basis Rich, Following (and attached) is the information on the backfit appeal I am working on. I appreciate your commitment to support the panel's effort to better understand and characterize the safety and risk significance of the plant configuration.

Gary Holahan or I will be in touch after we gather our thoughts and have a better idea about specific objectives and needs. As I mentioned to you, we will probably be looking for some transient analyses and risk assessments (using SPAR models). Steve Steven West, Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven.West@nrc.gov From: Holahan, Gary Sent: Thursday, June 23, 2016 10:44 AM To: West, Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Sea rbrough@nre.gov>;

Spencer, Michael <M ichael.Spencer@nrc.gov>

Cc: Clark, Theresa <Theresa.Clark@nrc.gov>

Subject:

FW: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(8).

GDC 15, GDC 21, GDC 29, and the Licensing Basis 3 (301) 415-1207 T-06/Fll Mailstop:

T-06/FI5 5

Subject:

Location:

Start: End: Recurrence

Meeting Status: Organizer:

Required Attendees: b ackfi t appea l pane l 0-16B6 Tue 07/12/20 1 6 1:00 PM Tue 0 7/12/2016 2: 00 PM (n o ne) Accepted CLAR K , THER E SA V HOLAHAN. GARY M; WEST. S t even S; SCARBROUGH, TH O MAS G; SPENCER, MICHAEL A Note that To m is~, bu t othe r s appear to be OK f or thi s o n e. [FYI didn't schedule for 7/7 as there wasn't a good lime for al LJ From: Sent: To:

Subject:

Corre i a , R i chard Thursda y , J u ly 0 7 , 2016 1 2:42 P M C lark , Th ere s a; Hol a ha n , G a ry; We st. Steven; Scarbro ugh, T homa s: S pen ce r, Michael R E: backf i t appea l pane l Don't worry about my schedule Theresa. I ca n easily adjust. Richard P. Correia., P.E. Dir ector , Di visio n o1 Risk AuahJsis OH ice o l Nucl ear R e eulat o ry Re sea r ch U.S.NRC -----Original AppointmentFrom: Clark, Theresa Sent: Thursday, July 0 7, 201612:18 P M To: Holahan, Gary; West , Steven; S carbrough , T homas; Spence r , M ich ael; Correia, Richard

Subject:

backfit appeal panel When: Thursday, July 14, 2016 10: 30 AM-11: 3 0 AM (UTC-05: 0 0) Eastern Time [US & Canada). Where: 0-1662 Note that S t eve will be on travel , bu t looks goo d for th e r est. I s h i ft ed by half an hour s o that Rich can join us for the seco nd p art (I think he has a m e et i ng till 11).

From: Sent: To: Cc:

Subject:

Ho l ahan , Gary Wednesday , July 13, 20 1 6 7:37 AM Clark, Theresa; West, Steven Scarb rough. Th o mas; Spe n ce r. Michael RE: CRGR Time S l ot With CRGR members only. We will talk to NRR separately. Best not to get involved in the normal CRGR business with NRR on a spec i fic issue. Gary From: Clark, Theresa Sent: Tuesday, July 12, 2016 6:27 PM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

West , Steven <Steven.West@nrc.gov>

Cc: Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>

Spencer, Mi chael <Michael.Spencer@nrc.gov>

Subject:

R e: CRGR Tim e Slot M eeting is with CRGR only or with the staff who wo uld have come to talk about the RIS? I got confused by the "the sta ff" below. Either is probably fine (and both may be needed eventually) but different topics. On: 12 July 2016 18:19, "Ho lahan , Gary" <Ga ry.Ho la h a n@nrc.gov>

wrote: Yes, I think it would be good to keep CRGR i nformed of our efforts and ear l y insights. Gary From: West, Steven Sent: Tuesday, July 12, 2016 6:13 PM To: Holahan, Gary <Gary.Holahan@nr c.g ov>

Subject:

Fwd: CRGR Tim e Slot Gary, Want to m ee t with the staff? Steve --------Original Message --------From: "Hackett, Edwin" <Edwin.H~ckett~nrc.qov>

Date: Tue , July 12, 2016 1 : 45 PM -0500 To: "West, Steven" <~teven.West(a:n~c..9.QY>

CC: "Cupidon, Les" <Les.C upidon@nrc.gov>, " Difrancesco, N icholas" <t.Jicholas.DiFrancesco@nrc.

gov>

Subject:

CRGR Time Slot Hi Steve, Per your previous email, are you and Gary still potentially interested in using the time slot we originally reserved for the CRGR meeting on Rev. 1 of RIS-2005-29? (July 21, 3-5 p.m.) Ed From: West, Steven Sent: Thursday, June 23, 2016 6:00 PM To: Hackett, Edwin <Edwin.Hackett@nrc.gov>;

DiFrancesco, Nicholas <Nicholas.DiFrancesco@nrc.gov>

Cc: Cupidon, Les <Les.Cupidon@nrc.gov>;

Moore, Scott <Scott.Moore@nrc.gov>;

McDermott, Brian <Brian.McDermott@nrc.gov>;

Williamson, Edward <Edward.Williamson@nrc.gov>;

Ordaz, Vanna <Vonn~.Ordaz@nrc.gov>;

Munday, Joel <Joel.Munday@nrc.gov>;

Wert, Leonard <Leof!ard.Wert@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

Clark, Theresa <Theresa.Clark@nrc.gov>

Subject:

RE: FYI* Backfit Panel Being Formed by OEDO Importance:

High Ed, If you haven't heard, l also "volunteered" to serve on the backfit appeal panel. I did not weigh in on your question about the CRGR meeting with the staff pending the appeal panel's kickoff meeting. We met this afternoon.

The panel will also be reviewing the proposed revision to the RIS_ During our kickoff meeting, among other things, we discussed coordination of the paners review with CRGRs review. In the short time available, we did not decide on any specific course of action. but agree that it was worthy of further discussion.

Before you change the CRGR's plans or cancel you meeting with the staff, I suggest you touch base with Gary and perhaps, if Gary agrees, come to one of our panel meetings to discuss with the entire appeal panel. One idea floated was that the appeal panel could take the CRGR's time slot with the staff. Steve Steven West. Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven.West@nrc.gov Edwin M Hackett Deputy Director, Office of Nuclear Regulatory Research U5NRC 301-415-1904 edwin.hackett@nrc.qov 2

Subject:

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Required Attendees:

backfit appea l panel 0-1602 Th u 07/1 4/20 16 10:30 AM Thu 07/14/2016 11: 30 A M (n one) Accepted Cla rk , Theresa H O LAHAN , GARY M; WEST, Steven S; SCAR BROUGH , THOMAS G; SPENCER, MICHAEL A; Correia , R i c ha rd Note that St eve will be on tr ave l. but looks goo d for th e r es t. I s h i ft ed by half an hour so that Rich ca n joi n us for the seco nd part (I think he has a meetin g till 11).

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Exelon backfit d i scuss i on HQ-OWF N-16806-1 2p Mon 07/18/20 16 12:30 P M Mon 07/18/2016 1: 30 PM (non e) Accepted Clark , There sa Required Attendees:

McGinty , Ti m; D SSCAL Resource; Holahan, G ary; West, Steven; Scarbrough, Thomas; Spe nc er, Michael Hi Tim , Thanks for being willing to meet with the EOO's appea l panel for the E x e l on backfit. As we discussed on the phone, you can bring staff if you would lik e to. H owever , yo u may n ot f e el th e n ee d at th i s point-we are intend in g for this to be a ca s ual conversation about the technical issues that led to the backfit and a ren't send i ng an y preparatory materials/questions.

If we need further discussions (e.g., with particular staff) after th is we c an certain l y do t hat. Also-I know this isn't a great time (a nd Steve has a potential conf l ict) b u t getting another time in the next two weeks was nigh on i mp ossible. Let me know if it i s really bad timing for you. Th anks! Background References

• Appeal pane l charter: ML16173A311

• 6/1 6/16 NEI letter s upp ort ing Exelon backfit appeal t o EOO: [attache d , not ye t in ADAMS) 2d i tem i s ML16208A008 , w h i ch

• 6/2/16 Exelon backfit appea l to EDO: M L1 61S4A2S4 is publi cl y a v a il a bl e i n ADAMS

• 5/3/16 NRR backfit appea l decision: M L 1609SA204

• 12/8/2015 E xe lon backfit app e al to NRR: ML1S342A112

• 10/9/2015 NRC b ackfit letter: ML142 2 SA871

• 8/26/04 pressurizer safety valve set p oin t safety eva l uat i on: ML0422S053 1

• 5/4/01 stretch power uprate safety evaluation

M L0 33040016 1 All docum e nt s li sted a r e publicly av a ilabl e in ADAM S From: Sent: To:

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Spen c er. Michael Monday. J u ly 18 , 2016 2:42 PM West. Ste v en Thursday Ba c kfit Pane l M e eting Steve , you mentioned a meeting on Thursday , but no such meeting is on my ca l endar. If th e Thursday meeting is for the backfit panel, could yo u forward that to me? Michael

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Good morning! Exelon backfit appeal w/ GSM EOO-OWFN-16B02-12p Tue 07/19/2016 1:00 PM Tue 07/19/20 16 2:00 PM (none) Accepted Clark, Theresa HOLAHAN , GARY M; SCARBROUGH, THOMAS G; WEST, Steven S; SPENCER, MICHAEL A; Mizuno , Geary As discussed between Margie and Gary, the ba ck f it appeal panel for t he B yr on/Braidwood PSV/PORV backflt would like to discuss the initial backfit review process wit h Geary Mizuno. This look s like the only t ime in the near-term that wi ll work for most. (Steve , I know you have a meeting but am hoping you m i ght be able to reschedule or have Brian cover it.) I don't believe any prep/questions/materials are needed Oust a c hat) but others on the panel c an correct me. Thanks, Theresa 1 From: Clark, Th e r esa Sent: Thursda y , Ju l y 1 4 , 2016 4: 58 PM To:

Subject:

Hola han , Gary; West. Steven; Scarbrough, Thomas; Spencer. Michael RE: Meeting with NRR agree From: Holahan, Gary Sent: Thursday, July 14, 2016 4: 57 PM To: Clark, Theresa <Theresa.Clark@nrc.gov>;

West , Steven <Steven.West@nrc.gov>;

Scarbrough , Thomas <Thomas.Scarbrough@nrc.go v>; Spencer , Michael <Michael.Spencer@nrc.gov>

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RE: Meeting with NRR No, that might look too demanding

... From: Clark, Theresa Sent: Thursday, July 14 , 2016 4:55 PM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

West , Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thoma s.Scarbrough@nrc.gov>;

S p ence r , Mi c ha e l <Michael.Spencer@nrc.gov>

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RE: Meeting with NRR Thanks, do you want me to inc l ude them i n t he appo i ntment / s hare with him? From: Holahan , Gary Sent: Thursday, July 14, 2016 4:52 P M To: Clark, Theresa <Theresa.Clark@nrc.gov>;

West , Ste ve n <Steve n.Wes t@nrc.go v>; Scarbrough, Thomas <Thomas.Scarbrough@nrc

.gov>; Spencer , Michael <Michael.Spencer@nrc.gov>

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RE: Meeting with NRR Yes , please set up the meeting. I read Tom's questions and think a discussion around them (no t a formal "please respond to the following

... ") w i ll b e good. Gary From: Clark, Theresa Sent: Thursday, July 14, 2016 4:50 PM To: Holahan , Gary <Gary.Holahan@nrc.gov>;

West, Ste v en <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc_gov>;

Spencer , Michael <Michael.Spencer@nrc.gov>

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RE: Meeting with NRR Not yet-I was about to schedule but was go ing to ask i f you wanted me to do t h at before we had the list of questions settled. From: Holahan, Gary Sent: Thursday , July 14 , 2016 4:49 PM To: West, Steven

<Steven.West@

nr c.gov>; Clark, Ther esa <Theres a.Clark@nrc.gov>; Scarbrough, Thomas <Thomas.Sca rbrough@nrc.gov>;

Spence r , Michael <Michael.Sp encer@n r c.gov>

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Meeting with NRR 1 All, Do we have a meeting NRR (Tim McGinty) set up yet? I don't want our CRGR discussion to get too far ahead of an NRR meeting. Gary 2 From: Sent: To: Cc: Subject H ola han , Gary Tuesda y. Ju l y 1 9 , 2016 3: 33 PM Sp en c er , Michael We st , Steven; Clark , The r esa; Scarbrough.

Thomas RE: E x e l on Backfit Appeal Yes, I'm about to add it to the refere nces also ... From: Spencer, Michael Sent: Tuesday , July 19, 2016 3:30 P M To: Holahan, Gary <Gary.Holahan@nrc.gov

> Cc: W est , Steven ; C lark , Ther esa ;

Scarbrough, Thoma s <Thomas.Sca rbrou gh@nrc.gov>

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RE: Exelon Backf it Appeal Gary, co uld you forward t his to us? M ic hael From: Holahan, Gary Sent: Tuesday, July 19, 2016 3: 27 PM To: Gody, T ony <Tony.Gody@nrc.gov>

Cc: West, Steven <Steven.West@nrc.gov>

C lark , Theresa <Theresa.Clark@nrc.gov>;

Scarbrough, Thomas ; S pen ce r, Michael <M ichael.Spencer@nrc.gov>

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RE: Ex e lon Ba c kfit Appea l Tony, Thanks for the docu m ent. .. v ery rele v ant to the backfit appeal panel effort. Although the panel has not made any final decis ions yet , we d id m ee t with NRR mana gemen t yesterday and asked the *'why did NRR not pursue a generic is su e resolution?" questio n. We'll keep you i nformed of the recommendat i o n we forward to the EDO. Thanks again, Gary From: Gady, Tony Sent: Tue sday, July 19 , 2016 8:5 1 A M To: Holahan , Gary <Gary.Holahan@n rc.g o v>

Subject:

Exelon Backfit Appeal Gary , I understand that this email i s uns o li c ited and yo u do not have to act on the attached information.

I am providing this memorandum to you f or yo ur co ns i derat i o n if you deem i t appropriate. Tony Gody, Dir ecto r Divi sio n of Reactor Safety Region II (404) 997-4600 ""'~ .. U.S.NR C 2 From: Sent: To:

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West , Steven Tuesday , J u ly 19. 2016 5:36 PM Holahan , Gary; Clark , Theresa; Scarbrough , Thomas; Spencer, Michael RE: Exelon Backtit Appeal I'd say this is definitely relevant information and germane to our review. Steve Steven West, Deputy Director Office of Nuclear Security and Incident Response U.S. Nu clear Regulatory Commission 301-287-3734 Steven.West@nrc.gov From: Holahan , Gary Sent: Tuesday, July 19, 2016 3:34 P M To: West, Steven <Steven.West@nrc.gov>;

Clark , Theresa <Theresa.Clark@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Spencer, Michael <M i chael.Spence r@nrc.gov>

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FW: Exelon Backfit Ap pea l From: Gody, Tony Sent: Tuesday, July 19, 2016 8:51 AM To: Holahan, Gary <Ga ry.H o lah an@nrc.g ov>

Subject:

Exelon Ba ckfit Appeal Gary, I understand that this email is unsolicited and you do not h ave t o act on the attached information.

I am providing this memorandum to you for your conside r ation if you deem it appropriate. T ony Gody, Director Division of Re ac tor Safety Region II (404) 997-4600 *t U.S.NRC

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Required Attendees: Hi a ll, Exe l on backfit appeal d iscussion with NRR/D E 0-1682 Wed 0 7/20/2 016 12: 30 PM Wed 07/20/2 016 1: 30 PM (non e) Accepted Cla rk , T heresa H olahan, Gary; West, S te ven; Scarb r ough , Thom as; S pencer, M ich ael; Lubinski.

John; Alle y , Da vi d; Billerbeck. John As noted by email , following their meet ing with DSS earlier to da y, the EDO-level appeal panel for the Exelon backfit (Byron/Braidwood PORV/PSV) would l ike to mee t with OE ma na gement/staff for an informal discussion of your revi ew r o l e in t h e 2015 back fit letter and a ssoci ate d inpu t s. I kn ow thi s isn't a perfect time for every o n e so I appreciate you r patience and willingness to meet. Thanks so much! The resa

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Cance le d: backfit appeal panel 0-1682 Wed 07/20/2016 1:00 PM Wed 07/20/2016 2:00 PM Free (none) Not yet responded Clark , Theresa High .,. cancelling just the old appointment

-NRR/DE appointment stands, and we'll have the room till 2 if we need it**

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When: Thu , Jul 21, 2016 , 3:00 PM Where: T-2B1 (ACRS Room) Confirmed: CRGR Formal R eview of Review of RIS 2005-29, Rev. l "Anticipated Tra nsien ts That Could Deve l op Into More Serious Events" HQ-T WFN 02 B0 1-ACRS R oom Thu 07/21/2016 3: 00 PM Th u 0 7/21/2016 5: 00 PM (non e) Accepted Cupido n. Les Cup id on. Les: Munday. Joel; Mcdermott , Brian; Williamson. Edward; Wert., Leo nard; Ordaz. Va nna: West. Steven; Ha ckett. Edwin; Mensah. Tanya; Whitman , Jennifer; Oesterle , Eric; S tu chell. Sheldon; Garmoe , Alex; Difrancesco.

Nicholas; Mcginty, Tim; Taylor. R obe rt Borromeo , Jos h u a; DSSCA L Resource; Spencer. Michael; Clark, Theresa I have cancelled the June 16th dale. We will meet in the ACRS confer ence room T2 B1. ~.

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Michael Spencer. Michae l T hursda y. Ju l y 21. 2016 4:13 PM Holahan , Gary; Clark , T heres a Ou r recor ds do n o t show an SRM for SECY-77-4 39. NFM From: Scarbrough , Thomas Sent: Monday , Ju l y 25. 2016 3:00 PM To:

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Holahan. Gary; West. Steven; Cl ark , Theresa; Spencer, Michael RE: safety v a lv es I will be there. Thanks. Tom From: Holahan , Gary Sent: Monday, July 25, 2016 2:36 PM To: Scarbrough, Thomas <Thomas.S c a rbr ough@nr c.gov>; West , Steven <Steven.West@nr c.gov>; Clark, Theresa <Theresa.Clark@nrc.gov>;

Spence r , Michael <Michae l.Spe ncer@n r c.gov>

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RE: safety valves We should talk ... tomorrow at 2pm From: Scarbrough, Thomas Sent: Monday, July 25 , 2016 12: 56 PM To: Holahan , Gary <Gary ,.Holahan@nrc

.gov>; West , Steven <Steven.West@nrc.gov>;

Clark, Theresa <Theresa.Clark@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>

Subject:

RE: safety valves If the NRC staff accepts the justification provided by a l icensee that a safety valve will not stick open, then the a open safety vafve would be counted as the single failure in the acc i dent analysis. Therefore, the licensee would not be required to assume another failure (such as l osing one ECCS train). This was the result of the staff position for the Byron/Braidwood Stretch Power Uprate that the safety valve would not stick open based on the EPRI test data. In the back.fit decision, the staff i s tak i ng the position tha t a stuck-open safety valve c an only be counted as the single failure if the valve is qualified per the ASME BPV Code (which would include liquid service certification).

Otherwise, the safety valve is assumed to stick open as a consequent i al failure caused by water relief. In answer to your question , the capability of a safety valve to reseat u nd er liquid service needs to be justified by the licensee for a stuck-open safety valve to be counted as the single fa i lure in the accident analysis. Thank s. Tom From: Holahan, Gary Sent; Monday , July 25, 2016 12:18 PM To: Scarbrough, Thomas <Thomas.Sca rbr o ug h@n r c.gov>; West, Steven <Steven.West@nrc.go~>;

Clark, Theresa ; Spencer , Mi c hael <Michae l.Spencer@nrc

.gov>

Subject:

RE: safety valves Thanks. Tom. Closer , understand that the .. co u l d .. means **wo u ld have to be considered as a single failure (not a consequential failure)".

Are you also say i ng that a stuck-open SV " is a legitimate single failure" or ~would l need to be justified as a single failure**

or **1s not usually assumed as a single failure**

or "there's no standard assumption"?

I think the answer will gets very close to a final position, Gary From: Scarbrough, Thomas Sent: Monday, July 25, 2016 11:18 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Clark, Theresa <Theresa.Clark@nrc.goJ!>i Spencer, Michael <Michael.Spencer@nrc.gov>

Subject:

RE: safety valves Gary, I used the phrase "could be considered a single failure" because the NRC staff made this finding (at least implicitly) as part of its review of the Byron/Braidwood Stretch Power Uprate. The staff at that time assumed that the safety valves would reseat with liquid service. Therefore, the staff would have considered the failure of a safety valve to reseat to be the single failure in an accident analysis.

Thanks. Tom From: Holahan, Gary Sent: Monday, July 25, 2016 11:01 AM To: Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Clark, Theresa <Theresa.Ctark@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>

Subject:

RE: safety valves Thanks Tom. Very helpful. One sentence confused me [3'd sentence of the last paragraph]: "In the case of a safety valve, I believe that the failure to reclose could be considered a single fal1ure if the NRC staff accepted the justification provided by the licensee that the valve will reliably reseat." I understand the rest of the paragraph and the "Therefore

... ", but the "could be considered a single failure" has me confused.

Gary From: Scarbrough, Thomas Sent: Monday, July 25, 2016 10:16 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Clark, Theresa <Theresa.Clark@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>

Subject:

RE: safety valves Gary, I agree that the vendor and ASME documents do not provide specific discussion regarding the potential for safety valves to stick open. However, the design and qualification of a safety valve must include its ability to reliably reclose. For example. the Crosby Engineering Handbook includes specific references to reclosing and 2 A passive failure in a fluid system means a breach in the fluid pressure boundary or a mechanical failure which adversely affects a flow path. Examples include the failure of a simple check valve to move to its correct position when required, the leakage of fluid from failed components, such as pipes and particularly through a failed seal at a valve or pump--or line blockage.

Motor-operated valves which have the source of power locked out are allowed to be treated as passive components.

In the study of passive failures it is current practice to assume fluid leakage owing to gross failure of a pump or valve seal during the long term cooling mode following a LOCA (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or greater after the event) but not pipe breaks. No other passive failures are required to be assumed because it is judged that compounding of probabilities associated with other types of passive failures.

following the pipe break associated with a LOCA, results in probabilities sufficiently small that they can be reasonably discounted without substantially affecting overall systems reliability.

It should be noted that components important to safety are designed to withstand hazardous events such as earthquakes.

Nevertheless. in keeping with the defense in depth approach, the staff does consider the effects of certain passive failures (e.g., check valve failure. medium or high energy pipe failure, valve stem or bonnet failure) as potential accident initiating events. Thus, the NRG staff allows check valves to be assumed to be passive components in certain instances under the Single Failure Criterion described in SECY-77-439.

With respect to squib valves, the NRC staff raised concerns during AP1000 vendor inspections regarding the potential for squib valves to open inadvertently.

In response, Westinghouse has included blocking features to avoid inadvertent opening of squib valves. AP1000 DCD Tier 2, Section 15.6.1 includes inadvertent opening of Stage 1 ADS valves (MOVs), but not Stage 4 ADS valves (squib valves). Therefore, the inadvertent opening of the ADS squib valves would be an example where this potential would be considered a single failure. In summary, the NRC staff allows some components to be assumed to be passive in evaluating single failures as described in SECY-77-439.

I believe that the reference to "under development" in 10 CFR Part 50, Appendix A, allows the NRC staff to make a case*by-case decision for a single failure assumption for a passive fluid component, and whether a "known and established standard" can be considered to exist regarding the performance of that component.

In the case of a safety valve, I believe that the failure to reclose could be considered a single failure if the NRC staff accepted the justification provided by the licensee that the valve will reliably reseat. The staff accepted the EPRI testing program for this justification for Byron and Braidwood during the Stretch Power Uprate review based on its evaluation of the EPRI test data without mandating that the safety valves be certified for liquid service by ASME and the National Board. Further, we have found a wide range of justification accepted by the NRC staff for the ~qualification" of safety and relief valves for liquid service in license amendments for other nuclear power plants. Therefore, I do not consider a specific "known and established standard" has been applied by the NRC staff in evaluating the acceptability of safety and relief valves to perform with liquid service. Nevertheless, I believe that licensees should avoid water relief through safety valves because they were not originally intended for this service, and the testing program performed by EPRI was limited in the sample size of valves tested and their range of service conditions.

Thanks. Tom From: Holahan, Gary Sent: Thursday, July 21, 2016 10:54 AM To: Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Clark, Theresa <!~eresa.Clark@nrc.gov>;

Spencer, Michael <Michaef.Spencer@nrc.gov>

Subject:

safety valves Tom, 4 reseating of its pressure relief valves. In addition, ASME Standard QME-1-2007 as accepted in RG 1.100 (Revision

3) defines a pressure relief assembly as follows: pressure relief valve assembly:

a valve assembly that is designed to open to prevent a rise of internal fluid pressure, in excess of a specified value, and re-close.

Mandatory Appendix I, "Qualification Specification for Active Valves," in ASME QME-1-2007 in Section OV-18000 states in item (h) that the specification must incfude blowdown (difference between set point pressure and reseating pressure).

Section QV-7660, "Functional Qualification," for safety and relief valves in ASME QME-1-2007 states that functional qualification for pressure relief valve assemblies shall be as delineated in ASME BPV Code, Section Ill, Subsections NB, NC, or ND 7000. Subsection NB-7000 in ASME BPV Code (2007 Edition) addresses the reclosing of safety valves in various paragraphs.

For example, item (k) in NB-7220. "Content of Report," in NB-7200, "Overpressure Protection Report," requires that the report shall include consideration of set pressure and blowdown limitations, taking into account opening pressure tolerances and overpressure of the pressure relief device. In addition, NB-7512.3, "Blowdown," for safety valve operating requirements specifies that the safety valves shall be adjusted to close after blowing down to a pressure not lower than 95% of the set pressure unless a different percentage is specified in the design specification and the basis is covered in the Overpressure Protection Report. Therefore, the design and qualification of a safety valve include its ability to reclose reliably to be able to satisfy its blowdown requirements.

Until the TMl-2 accident, I do not believe that there was much concern regarding safety and relief valves sticking open. It was assumed that the simple spring-loaded design of safety valves provided reasonable assurance that this valve design was not subject to a significant concern regarding failure to reclose. In response to the TMl-2 accident.

NUREG-0737 included Mqualification" requirements to provide confidence that safety and relief valves would not stick open under various steam and liquid conditions.

However, NUREG~ 0737 did not require that safety and relief valves be "certified'" for all service conditions.

The EPRI testing program in response to NUREG-0737 was limited in its extent of testing. but did confirm that a generic problem did not exist regarding safety and relief valves sticking open under various conditions.

SRP Section 15.6.1 (2007), "Inadvertent Opening of a PWR Pressurizer Pressure Relief Valve or a BWR Pressure Relief Valve," provides a requirement to evaluate an inadvertent opening of a PWR safety valve. SRP 15.6.1 states that a pressure relief valve, as defined in ANSI 895.1-1972, is a device designed to reclose and prevent further fluid flow after normal conditions are restored.

The SRP section does not provide details regarding the assumption for the safety valve to stick open. However, AP1000 OCO Tier 2, Section 15.6.1, states that the "inadvertent opening of a pressurizer safety valve can only be postulated due to a mechanical failure." The AP1000 accident analysis assumes that the safety valve remains open throughout the event. Check valves are considered passive components in some instances (such as system design) and active components in other instances (such as the 1ST Program).

NUREG-1482 (Revision

2) states in Section 4.1 that SECY-77-439, Single Failure Criterion," dakd August 17, 1977, which was referenced in several plants' licensing bases, discusses thc failure 0f a check \'alvc t0 1110\'e to its correct ()(lsition as a passive failure; however, this docs not c<1rrespond to the i.s.sue of "active**

versus .. passive

for the purpose of 1ST. In Section 2, SECY-77-439 (ADA~S No. ML060260236) states the following:

D. Passive Failure in a Fluid System 3 This is your area ... but I did check the Byron and Braidwood UFSAR and the Crosby Engineering Handbook (both added to the References).

Neither speaks to safety valve re-closure as a "protection function" or even as a requirement (for either liquid or stream relief). Safety valves are clearly designed to re-close {as opposed to rupture disks and other "non-rec/osure" devices), but the Code and designer requirements seem to be limited to set-points and capacities.

Could it be that "failure to close" for a simple spring-loaded safety valve to considered a "passive failure" like pipe ruptures (or a valve bonnet rupture)?

... and therefore not required or addressed in safety analyses?

Are there other components or functions that we just don't address as potential single failures or consequential failures because they are considered so unlikely?

Check valves? The introduction says {in a footnote), Single failures of passive components in electric systems should be assumed in designing against a single failure. The conditions under which a single failure of a passive component in a fluid svstem should be considered in designing the system against o single failure are under development.

Does "under development" sound like a "known and established standard of the Commission?" Could the answer be related to definition of and practice on "consequential failures"?

Is "not designed for" or "not certified to" the standard?

Or is "not expected to function" or "not assured to function" or "not demonstrated to" the standard?

Or is there no standard?

Maybe the Panel shouldn't need to be working on such fundamental issues, but there doesn't seem to be an answers for such questions

... Gary 5

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Hi all, Exelon ba c kfit appeal w/ FMA T-6F34 Tu e 07/26/2016 2: 00 PM Tue 07/26/2016 3: 00 PM (none) Accepted Clark. Theresa Aks t ulewicz. Frank; Holahan. Gary; WEST. Steven S; SPE NC E R , MICHAEL A; SCAR BROU GH. TH OMAS G As noted by email, the EDO-le v el appeal panel for the E xelon backfit (Byron/Braidwood PORV/PSV) would l ike to meet with F rank for an informal di s cuss i on o f his re c ollect i on of the original 200 1 stretch p ower uprate that is brought up in the context of the appeal. I know this isn't a perfect time f or everyone (I think it'll be Gary , M ic hael, and me only with Frank) so I ap pre ci at e eve ry one's flexibility). Thank s so mu c h I T her es a

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Required Attendees: back fi t appeal pa nel 0-16B6 Wed 0 7/27/2 016 2: 00 PM Wed 0 7/27/2 016 3: 0 0 PM (n o ne) Accep ted CL ARK , THERESA V H O LAH AN , GARY M: WEST. Steven S; SCAR BR OUG H. THOMA S G; S PEN C ER, MICHAEL A I think Steve and Tom are b o th o ut , but b l ock i n g fo r Ga ry and M ich ae l a n y wa y. [FYI, only meeting this week given two all-da y Commission meet i ngs on 7/26 and 7/28.[

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Thank you. Tom From: Scarbrough, Thomas Holahan , Gary F r iday , July 29 , 2016 3: 00 PM Scarbrough , Thomas; Spence r , Michael: Clark. Theresa; West, Steven RE: A New attempt at " Crisp" Sent: Friday, July 29, 2016 2:59 PM To: Spencer, Michael <Michael.Spencer@nrc.gov>

Clark , Theresa <lh eresa.Clark@nrc.gov>;

Holahan, Gary <Gary.Ho/ahan@nrc.gov>;

West, Steven <Steve n.West@nrc.gov>

Subject:

RE: A New at t em pt at " Crisp" I am fine with the latest version. Thanks. Tom From: Spencer, Michael Sent: Friday, July 29, 2016 1:14 PM To: Clark, Theresa <Theresa.Clark@nrc.gov>;

H o lahan , Gary <G a ry.Hol a han@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Scarbrough, Th omas <Thomas.Scarbrough@nrc.gov>

Subject:

RE: A New attempt at " Crisp" I'm happy with the document.

No mo r e comments.

From: Clark, Theresa Sent: Friday , July 29, 2016 1:09 PM To: Spencer, Michael <Michae l.Spencer@nrc

.gov>; Holahan , Gary <Gar v.H o lahan@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Scarbrough, Th omas <Tho mas.Scarbrough@nrc.gov>

Subject:

RE: A New attempt at " Crisp" I added that sentence in ... From: Spencer, Michael Sent: Friday, July 29 , 2016 12:16 PM To: Holahan, Gary <Gary.Holahan@nrc

.gov>; Clark, Theresa ; West, Steven <Steven.West@nrc.gov>;

Scarbrough , Thomas <T ho mas.Scarbrough@nrc

.gov>

Subject:

RE: A New attempt at " Crisp" I very much like the addition , but now I see some tension with the following sentence in the first paragraph:

" The Panel concludes that in 2001 and 2004 there was no known and established standard of the Commission relating to the potential o f pressurizer safety valves (PSVs) to fail following water discharge during Inadvertent Operation of Emergency Core Cooling System (ECCS) events." P erhaps we could replace the sentence in th e first paragraph with a sentence based on your addition, something like: ~The panel concludes that in 2001, 2004, and at present, the known and established standard of the Commission is that the probability of failure of p res sur i zer safety valves (PSVs) following water discharge during Inadvertent Operation of Emergency Core Cooling System (ECCS) should be sufficiently small based on well-informed staff engineering judgment." Michael From: Holahan, Gary Sent: Friday, July 29, 201611:52 AM To: Spencer, Michael <Michael.Spencer@nrc.gov>;

Clark, Theresa <Theresa.Clark@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>

Subject:

RE: A New attempt at "Crisp" I agree. Re-formatting and recent comments all look very good. I accepted all and added one. Please see the latest version in Report folder ... attempting to articulate current standard as: ... The panel concludes that the standard, for not assuming valve failure, in place in 2001, 2004 and at present is simply that the probability offailure of PS Vis sufficiently small, based on well-informed staff engineering judgement; and that the use of the word "qualified" or "qualification" implied only a general demonstration of capability, such as in the EPRI testing done in response to TM/ Action Plan. From: Spencer, Michael Sent: Friday, July 29, 2016 10:49 AM To: Clark, Theresa <Theresa.Clark@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Holahan, Gary <Gary. Holahan@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nre.gov>

Subject:

RE: A New attempt at "Crisp" Great job. I really like how the reformatting organizes the various points. My only comment is: on the last page there should be a space between the paragraph starting "Moreover"'

and the paragraph starting "The panel concludes." Michael From: Clark, Theresa Sent: Friday, July 29, 2016 10:37 AM To: West, Steven <5teven.West@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>

Subject:

RE: A New attempt at "Crisp" I edited/reformatted somewhat and incorporated Steve's comments.

I don't think I made any substantive changes (especially that Tom would have an issue with, since he is away from his computer for most of the day) but thought some formatting might help it read better. You may wish to view the attached in "No Markup" mode on the "Review" tab so it doesn't look messy. I already accepted all of the formatting changes. Gary, I know you are working a version too. This one is also in the S: drive. From: West, Steven Sent: Friday, July 29, 201610:32 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Clark, Theresa 2

<Theresa.Clark@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>

Subjett: RE: A New attempt at "Crisp" Gary, Nice! See my attached markup for a few corrections and suggestions.

We don't need to address it in the Crisp document, but I suggest we talk about if and how we should address the staffs apparent failure to treat this issue generically in accordance with its procedures.

Steve --------Original Message --------From: "Holahan, Gary" <Gary.Holahan(iilnrc.gov>

Date: Fri, July 29, 2016 8: 16 AM -0500 To: "Scarbrough, Thomas" <Thomas.Scarbrough@nrc.gov>, "West, Steven" <Steven.West{runrc.gov>, "Clark, Theresa" <Theresa.

Cla rk@nrc.gov

>, "Spencer, Michael" < Michael.Spencer@'

n re.gov>

Subject:

RE: A New attempt at "Crisp" Thanks Tom, got it. From: Scarbrough, Thomas Sent: Friday, July 29, 2016 7:08 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

West, Steven <Steve!'lWest@nrc.gov>;

Clark, Theresa <The resa.Clark@nrc.gov>;

Spencer, M ichae I < Michael.Spencer@nrc._go~>

Subject:

RE: A New attempt at "Crisp" I am fine with the crisp summary. We could add another sentence at the end of the Beaver Valley 2006 paragraph to identify the wide-spread reference to the EPR1 program, such as: In addition, the panel found general references to EPRI and vendor testing for the capability of SVs and PORVs in licem,e amendments for other nuclear power plants. I see a few minor typographical edits (such as use of SV and PSV), but I am sure that Theresa will identify those items. Thanks. Tom From: Holahan, Gary Sent: Thursday, July 28, 2016 5:01 PM To: West, Steven <Steven.West@nrc.gov>;

Clark, Theresa <Theresa.Clark@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Spencer, Michael <Michael.Spencer@rJ!C.gov>

Subject:

A New attempt at "Crisp" Steve, Tom, Michael, Theresa, Please see attached.

I have cut the 4-pager in half to make it a "crisp" summary of preliminary findings far OEDO, NRR, and OGC. 3 The longer write-ups look like good input to the final report. Please review and comment. Gary 4 From: Sent: To:

Subject:

Panel , Ho l ahan. Ga ry Frida y. Ju l y 29 , 2016 3: 5 1 PM West. S te ven; C l ark , T heresa; Sc arb ro ugh , T homas; S pencer, Michael Prelim i nary Fi ndi n gs Thanks to all outstanding (preliminary) effort. I p lan on deliver i ng the 7/2 9/16 3pm version to Vic, Mike, and Glenn on Monday morning . . . . And then deliver it to NRR and OGC on Tuesday, if we don't get OEDO comments.

Gary From: Sent: To: Cc:

Subject:

Thanks Gary. From: Holahan , Gary Johnso n , Mi c hael Sunday , July 31 , 2016 9: 10 AM Ho lahan , Gary; M cc ree , V i ctor; T r ac y , Glenn; Dean. Bill; Lub ins ki , John; Mcginty. T i m; Akstulewicz , F r ank; Doan e. Margaret Hackett. Edw i n; West. Steven; Cl a rk , Theresa; Scarbrough, Thomas; Spencer, Michael; Evans. M i c he l e; M c d er mott. B r i an; Will i amson. E dward; M i zuno, Geary; Shuaibi, Mohammed RE: P reliminary Findings of the Exelon Backf t t Panel -ODO-Pr@-t1et isi o11 a1 I mel 11&H RE ~se 01119 . Sent: Friday, July 29, 2016 1:58 PM To: Mccree, Victor <Victor.McCree@nrc.gov

>; John so n , Michae l <M ichael.Johnson@

nrc.gov>; Tr acy, Glenn <Glenn.Tracy@nrc.gov>; Dean , Bill <Bil l.De an@n rc.gov>; Lubinski, John <John.l ubinski@nrc.gov>; Mcginty, Tim <Tim.McGinty@nrc.gov>

Akstu lewicz , Frank <Fr a nk.Akstu lew ic z@nrc.gov>; Doane, Margaret <Margaret.Doane@nrc.gov>

Cc: H ac kett, Edwin <Edwin.Ha c k ett@nr c.go v>; West , Ste ven <Steven.We s t@nr c.g ov>; Clar k , Ther esa <Theresa.Clark@nrc.gov>

Scarbrough , Th omas <Thomas.Sca rbrough@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.go v>; E vans, Miche l e <Michele.E v a ns@nrc.go v>; Mcdermott, Brian <Brian.M cD ermott@nr c.gov>; William so n , Edward <Edwar d.Wi ll i am son@nrc.gov>;

Mi zu no , Geary <Geary.Mizuno@nrc

.gov>; Shua i bi , Mohammed <Mohammed.5hu a i bi@nr c.gov>

Subject:

Preliminary Findings of the Exelon Backfit Panel*~?. t d e cisiona l I.ate, 11&1 W'lC tl s e-8~ Importance

High Vic, Margie, Mike , Glenn. Bill, John, Tim, Frank, Based on a review of more than 50 documents (coveri n g a period from 1971 to the present), and dis c ussions with OGC staff, NRR staff, former NRR staff. and the CRGR , the Exe lon Ba ckfit Panel has developed Preliminary findings that i t bel ieves shou ld be sha r ed w i t h NR C internal stakeholders. Here is the Exelon Backfit Panel's roll-out plan for completing i ts work: 8/1/16 Pro vide Pr eliminary F indings to OEDO for i nfo rmation and feedback on s co pe and depth-of-review and other expectations 8/2/16 Provide Preliminary Find in gs t o NRR (and former NRR staff) and OGC for completeness and accuracy .. ."fact check in g" 8/9/16 Collect any comments 819/16 RES provides insigh ts o n risk and s af e ty significance 8/19/16 Prepare Draft final Report with findin gs , response to questions, and recommendations.

8/29/16 Provide final Report to EDO The Panel will be available for discussion of any issues or concerns during the weeks of 8/1/16 and 8/8/16. Gary 2 From: Holahan , Gary Sent: Thursday , August 04 , 2016 4: 07 PM To:

Subject:

S p encer, Mi c hael; West. Steven; S c arbroug h, Thomas; Clark, Theresa RE: Things to revie w Very good , Thanks, Yes we need RES for 05 All, Please work hard while rm of tomorrow. Gary From: Spencer , Michael Sent: Thursday, August 04, 2016 4:0 2 PM To: Holahan , Gary <Gary.H olaha n@nr c.gov>; West , Steven <Ste ve n.West@nr c.gov>; Scarbrough, Thoma s <Thornas.Scarbrough@nrc.gov>

Clark , Theresa <Theresa.Clark@nrc.gov>

Subject:

RE: Things to review I have provided comments on the co ve r memo , w h i ch i s saved on the S: drive. I suggest that we include brief responses to the 5 questions the EDO asked us. I have cop i ed the questions and suggested brief responses to the first four of them (based in large part o n disc uss ion already developed}. Presumably, we need to wait on RES to answer the 5th question. Michael From: Holahan, Gary Sent: Wednesday, August 03 , 2016 4: 58 PM To: West, S teven

Scarbrough , Tho mas <Thomas.Scarbrough@nrc.gov>

Clark , Ther es a <Theresa.Clark@nrc.gov>;

Spencer, Michael <Michael.Spe n cer@nrc.gov>

Subject:

Things to review Steve, Tom, Michael , Theresa, I have taken the Preliminary Findin gs document and inc orpora ted it in to a "Discussion" se ction. I added text to make it read like a report (no changes to findings or conclusions

). Please review at Reports/ Backfit Appeal Report 2016 08 03 2pm. Next I will start on the Enclosures (and the sections referrin g to them). I have also drafted (fi rst draft ... ) a memo to V ic presenting the report. Please review at Reports/ Cover memo Backfit Appeal Panel 2016 08 03 2pm. Gary 1 P.S. I told Vic that I promoted you to team member, so he won't be surprise to see your name on the cover memo. 2 From: Sent: To:

Subject:

Holahan. Gary Monday , August 08 , 2016 12: 59 PM West. Steven; Spencer , Michael; C l ark , Theresa; Scarbrough, T homas RE: backfit a ppea l panel meeting I have not heard that NRR is ready to withdraw t h e backfit. I'm exp ecting t echn ical comments. I have not heard any reques ts for a meeting ei t he r. If they do have comments. we should consider having a meeting with them (whether they ask or not). Gary From; West , Steven Sent: Monday , August 08 , 2016 12: 45 PM To: Spen c er, Mi c hael <Mi c hael.Spe nc er@nr c.g ov>; Clark , Theresa <The re sa.C l ark@nrc.gov>;

Holahan, Gary <G ary.Holahan@nrc.gov>; Scarbrough, Th o ma s <T homas.Scarbrough@nrc.gov>

Subject:

RE: backfit appeal panel meeting That's an interesting ques tion. P r esumably. i f th at were to happen. we would still document the results of our review? (I heard through the grapevine that NRR was p r eparing comments, but nothing about the nature of th os e comments.) Steve Steven West , Deputy Director Office of Nuclear Security and Inciden t Re spo ns e U.S. Nuclear Regulatory Commission 301-287-3734 Steven.West@nrc.gov From: Spencer, Mi chael Sent: Monday , August 08 , 2016 12:42 PM To: Clark, Theresa <Theresa.C 1 a rk@n rc.g ov>; Holahan , Gary <Gary.Hola h an@nrc.gov

>; West, Steven ; Scarb r ough, Th o ma s <Tho mas.S c arbrough@nrc.gov>

Subject:

RE: ba c kfit appeal p ane l me etin g I s th e r e any hint as to whether NRR will w ithdraw th e baci<f it?

From: Clark, Theresa Sent: Monday, August 08, 2016 12:33 PM To: Spencer, Michael <Michael.Spencer@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>

Subject:

RE: backfit appeal panel meeting I'll see what I can find. August 10 was looking messy when l checked over the weekend. I think there might be a few items from the report to discuss even in the absence of comments.

NRR said this morning we'd have them tomorrow or Wednesday.

From: Spencer, Michael Sent: Monday, August 08, 2016 12:31 PM To: Clark, Theresa <Theresa.Clark@nrc.gov>;

Holahan, Gary <Gary.Holahan@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>

Subject:

RE: backfit appeal panel meeting We had requested comments by tomorrow.

Unless we have already received NRRs comments, then it might be better to meet on August 10 so we could discuss any comments we receive tomorrow.

Michael ---*-Original From: Clark, Theresa Sent: Saturday, August 06, 2016 11:23 PM To: Clark, Theresa; Holahan, Gary; West, Steven; Spencer, Michael; Scarbrough, Thomas

Subject:

backfit appeal panel meeting When: Tuesday, August 09, 2016 11:00 AM-12:00 PM (UTC-05:00)

Eastern Time (US & Canada). Where: HQ-OWFN-11B02-12p Just realized we didn't have any more meetings scheduled!

T 2 From: Holahan , Gary Sent: Monda y. August 08 , 2016 1: 11 PM To:

Subject:

West , Steven; Clark , Theresa; Scarbrough , T homas; Spencer, Michael RE: Things to review Now that there is a "clean" Saturday version to work from (tha nks , The resa), I think further re vi ew and comment is OK. Gary From: West, Steven Sent: Monday, August 08, 2016 1: 03 PM To: Holahan , Gary <Gary.Holahan@nrc.g ov>; Clark , There sa <T heresa.Clark@nrc.gov>;

Scarbrough , Thoma s <Thomas.Scarbrough@nrc

.go v>; Spencer, Mi c h ael <M ic hael.Spe n ce r@nrc.gov>

Subject:

RE: Things to review Would it be better fo r us to hold off commenting u nt i l afte r you comp lete your current review and r e vis ion? Steve Steven West , Dep uty Dire ct or Offi ce of Nu clear Se c urity and In cident Re sponse U.S. Nuclear Regulatory Comm is sion 301-2 87 -37 34 Steven.West@nrc.gov From: Holahan, Gary Sent: Mond ay, Augu st 08, 2016 10: 34 AM To: Clark , There s a ; We s t , Steven <Stev en.We s t@nr c.go v>; Sca rbr o u g h , Th omas <Thomas.S carbro ugh@nrc.gov>;

Spen cer , Michae l <Mi chael.Spe nc er@nrc.gov> Subj ect: RE: Things to review Theresa , Thank you. The re port l ooks g reat. I'm re-reading and fill ig in t he b la nks and refe re nces as I go. Gary From: Clark , There s a Sent: Saturday , August 06, 201611: 27 PM To: Hol ahan, Gary <Gary.H o lah an@nr c.g ov>; West , S t even ;

Scarbrough, T hom as ; Spencer, Michae l <M i chael.Spence r@nrc.gov>

Subject:

RE: Thi ngs to review 1 Gentlemen, No t e: T h e blacke n ed o ut texx t actua l ly i s pi nk hi ghl i g hti ng i n the orig i na l. T he h i gh l ig h ted wo rd s a re " pink hi g hli g hts." We're really getting the re. I took the files prepared t o date (memo incl uding Michael's comments, Gary's report file, and Tom's enclosures file) and created two cle an fi l es that have been formatted, edited, and otherwise prettified and such. I added some comments in the margin where I wasn't quite sure about th ings. Yellow highlights are for references that will need to (eventually) be put into a sing le format with a si ngle list at t he end-my ne xt big projec t, I think .* -are inserts for the future.

• S:\Backfit-Appeal\Report\cover memo (clean as of 2016 08 06 11pm).docx

• S:\Backfi t-Appeal\Report\Backfit Appeal Panel Report {clean as of 2016 08 06 11pm).docx Just because it looks all nice doesn't mean it's done (or that my edits were necessar ily correct-note that we can do a compare to the la st version if needed, since I accep ted all of the messy changes).

But , like I said, getting there. I just set up a meeting for Tuesday since we didn't have any more on the calendar, and I can set more thereafter as needed. Thank s! Theresa Valentine Clark Executive Technical Assistant (Reactors)

U.S. Nuclear Regulatory Commission Theresa.Clark@nrc

.go v I 301-41S-4048 I 0-16 E 22 From: Holahan , Gary Sent: Wednesday, August 03 , 2016 4:58 PM To: West , Steven ; Scarbrough , Thomas <T homas.Scarbro ugh@nrc.gov>; Clark, Theresa <Theresa.Clark@nrc

.gov>; Spencer , Michael <Mic hael.Sp encer@nrc.gov>

Subject:

Things to review Steve, Tom, Michael, Theresa , I have taken the Preliminary F i ndings document and incorpora te d it into a " Discusslon" section. I added text to make it read like a report (no changes to findings or conclusions). P le ase review at Reports/ Backfit Appeal Report 2016 08 03 2pm. Next I will start on the Enclosures (and the sections referring to them). I have also drafted (first draft. .. ) a memo to Vic pre sen ting the report. Please review at Reports / Cover memo Backfit Appeal Panel 2016 08 03 2pm. Gary 2

Subject:

Location: Start: End: Recurrence

Meeting Status: Organizer: Required Attendees: back fi t appeal pane l m e et i ng HQ* OWFN-11B02-1 2p Tue 08/09/2016 11: 00 AM Tu e 08/09/2016 12: 00 PM (none) Accepted Clark , Theresa Holahan , Gary; West , Steven; S pencer , M i chael; Scarbrough, Thomas Ju st realized we didn't have any more meetings scheduled!

T

Subject:

Location:

Start: End: Recurrence

Meeting Status: Organizer:

Required Attendees:

backfit appea l panel HQ-OWF N-16 B 06-l2p Thu 08/11/2 0 16 1 2: 00 PM Th u 08/11/20 1 6 1: 00 PM (n o n e) Accep ted Cla rk , Theresa Holahan , Ga ry; Wes t , Steven; Scarbrough , Thom as; Spencer, Mi c hael This is just a placeholder.

I'm fully aware that mee tin gs a t noon are inhum ane. I j ust don't see another option if we do want to m eet T h u rsday. Mor e to co m e©. Theresa From: Sent: To: Cc:

Subject:

Clark , Ther esa Thurs day , A u g us t 11. 2016 1:16 PM Ho l a h an , Gary West , Steven; Scarbrough. Thomas; Spencer , Michael Re: REQUEST: b a ckfit appeal p a nel meeting w/ Vic T hat was the intent of my "Mike m ay a l so w i s h t o attend." H e i s free at th e sugges t ed time so I'll make sure P a tti includes. Thanks! On: 11 Augu s t 2016 13:14 , " H olahan, Gary" <Ga r y.Holahan@nrc

.g<w> wrote: How about inviting Mike Johnson? From: Clark, Theresa Sent: Thur s day , August 11 , 2016 1:04 PM To: Sprogeris, Patricia <Patr ic ia.S pr og e ris@nrc.gov>

Cc: Holahan, Gary <Gary.Ho lahan@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas ; S p encer, Michael <Michael.S p e n cer@nrc.gov>

Subject:

REQUEST: backfit appeal panel meeting w/ V ic Patti, Can you please arrange a meeting for the backf i t ap p e a l panel {Gary Holahan, Steve West, Tom Scarbrough, and Michael Spencer) with Vic? Mike may also wish to a tten d. T he week of August 22 would be idea l , perh ap s 11am 8/24 for half a n hour if Gary and S t ev e c an make that work (others are fr ee). Otherwise , please work your magic to find a time. Thanks! Theresa Valentine Clark Executive Technical Assistant (Rea ctor s) U.S. Nu c lear Regulatory Commission Th eresa.Clark@n r c.gov j 301-415-4 048 I 0-16E22 From: Sent: To: Cc:

Subject:

West. Steven Thursday. August 11. 2016 624 PM Ho lahan. Gary; Cor re i a , Richard; Scarbrough.

Thomas; Spencer, Michael; Clark, Theresa Weber. Michael; Hackett. Edwin; Thaggard , Mark; Coyne, Kevin RE: Memorandum From: V. McCree to G. Holahan re: Charter for Backfit Appeal Review Pa n el Assoc i ated with Byron and Braidwood Compliance with 10 CFR 5034{8), GDC 15, GDC 21. GDC 2 9 , and t he Licensing Basis Looks like good airplane reading for me next week! Steve Steven West, Deputy Director Office of Nuclear Security and In c i dent Re sponse U.S. Nu c le ar Regulatory Commission 301-287-3734 Steven.West@nr c.gov From: Holahan, Gary Sent: Thursday , August 11, 2016 6: 21 PM To: West, Steven <Steven.West@nrc.gov>;

Correia , Richard <Richa rd.Correia@nrc.gov>;

Scarbrough, Thomas <T homas.S carbrough@nrc.gov>;

Spencer, Michael <Mic ha el.Spencer@nrc.gov>;

Clark, There sa <Theresa.Clark@nrc.gov>

Cc: Weber, Michael <Michael.Weber@nrc.gov>;

Hackett , Ed w i n <Edwin.Hackett@nrc.gov>;

Thaggard, Mark <Mark.Thaggard@nrc.gov>;

Coyne , Kevin <Kevin.Coyne@nrc.gov>

Subject:

RE: Memorandum From: V. Mccree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.3 4(8). GDC 15 , GOC 21 , GDC 29, and the Licensing Basis Thanks from me also. Ri c h. Looks like we will be studying the report for a wh i le. Gary From: W est, Steven Sent: Thursday , August 11, 2016 6: 12 PM To: Correia, Richard <Richard.Correia@nrc.gov>

Ho l aha n, Gary <G ary.Holahan@nrc.gov>;

Scarbrough, Thomas <Thomas.Sc arbrough@nrc

.gov>; Spencer, Michael <Michael.Sp e ncer@nrc.gov>; Clark, There s a <Theresa.

Cla rk@nr c.gov> Cc: Weber , Michael <Michael.Weber@nrc

.gov>; Ha cket t , Edwi n <Edwin.Hack ett@nrc.gov>; Thaggard, Mark <Mark.Thagg ard@nrc.gov>;

Coyne, Kevin <Kevin.Coyne@n r c.gov>

Subject:

RE: Memorandum From: V. Mccree to G. Hol ahan re; Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR S0.34(B), GDC 15 , GOC 21, GDC 29, and the Licensin g Basis Thanks, Rich. This helps answer an important question and will be very helpful to the panel. Please pass on my sincere thanks to all of the contributors. Steve Steven West, Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven.West@nrc.gov From: Correia, Richard Sent: Thursday, August 11 , 2016 5:54 PM To: Holahan , Gary <Gary.Holahan@nrc.gov>;

West , Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>

Spencer, M ichae l <Mic hael.Spencer@nrc.gov>;

Clark, Theresa <Ther esa.C 1ark@nrc.gov

> Cc: Weber, Michael <Michael.Weber@nrc.gov>

Hackett, E dwin <Edwin.Hackett@nrc.gov>;

Thaggard , Mark <Mark.Thaggard@nrc.gov>;

Coyne , Kevin <Kevin.Coyne@nrc.gov>

Subject:

Memorandum Fr om: V. M ccree to G. Hol ahan r e: Charter for Backfit Appeal R ev iew Panel Associated with Byron and Braidwood Compliance with 10 CFR 50.34(8), GDC 15 , GDC 21 , GDC 29 , and the Licensing Basis Importance:

High Gary et al., The attached risk assessment report ad dre sses the Byron/Braidwood backit issue. The conclusion is that the maximum benefit from a potential b ackfit remed y w ould prov i de a very small reduction in risk (i.e., less than 1 E-06/year).

It should be noted that the analysis contained i n the report was narrowly focused on the backfit question under review by the Appeal Re view Bo a rd and is i ntended to provide additional context and insights to the Board. As such , other applications of this informa tion may not be appropriate unless this limitation is recognized.

Please let me know if you need any addit i onal info rmation or i f you would like a briefing.

Regard s Richard P. Correia, P.E Dir ector, Divisioll ol Risk A11a h 1sis Office a£ Nuclear Re5ul..0.itonJ Research U.S.NRC 2 From: Sent: To: Cc:

Subject:

Cor r eia , Ri c h a r d Fr iday, A ugust 12 , 2016 9:33 AM West. Steven; Holahan , Gary; Scarbrough, Thomas; Spencer. Michael; Clark, Th e r esa Weber , Michael; Hac ke tt. Edwin; Thaggard.

Mark; Coyne. Kevin Re: Memorandum F ro m: V. Mccr ee to G. Ho lah an re: Charter for Backfit Appeal Review Pa nel Associ at ed w ith B yron and B raidwood Co mpliance with 10 CFR 5 0.34(8), GDC 15, GDC 21. GDC 29 , and the Li c ens ing Bas is You are most welcome Steve and t ha n ks for the opportunity. Very i ntere st ing analysis.

We need to do more to support de c i sio n s like t hi s. I will pas s on thank s t o all.best Rich Ri char d Correia, P.E. Direct or, Divi s i o n of Ri s k Ana l ys is Office of Nuclear Regulator y Re s e arc h U SNRC On: 11 August 2016 I 8:11 , "Wes t , St e ve n" <St e ve n.We s t@nrc.g o v> w rote: Thanks, Rich. This helps answer an im porta n t question a nd w i ll be ver y helpful to the panel. Please pass on my s inc e r e thank s to all of the contributors. Steve Steven West , D e puty Director Office of Nu clea r Security a nd In c ident Re s p o n se U.S. Nu c lear R egulatory Commission 30'1-287-3734 St eve n.W es t@nr c.gov From: Correia, Richard Sent: Thursday, August 11 , 2016 5: 54 P M To: Holahan , Gary <Gary.Holahan@nrc.gov>;

West, Steven <St e v en.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Sc arbrough@nrc.g ov>; S pen ce r , Mic ha e l <Mi ch ael.S p encer@nr c.gov>; Clark , The r esa <Theresa.Clark@nrc.gov>

Cc: Weber, Michael <Micha el.Webe r@nrc.go v>; H ackett, E d win <Edwin.H a ckett@nrc.gov>;

Thaggard , Mark <M ar k.T h agga rd@n rc.gov>; Coyne, K evin <Kev in.Coy n e@nrc.g ov>

Subject:

Memorandum From: V. Mccree to G. Holaha n r e: Charter for Ba ckfit Appeal R evie w Panel As s ociated with Byron and B r aidwo o d Complia n ce with 10 CFR 50.34(8), GD C 15 , GDC 21, GDC 29, and th e Licensing Basis Importance

Hi gh Gary et al..

The attached risk assessment report addresses the Byron/Braidwood backit issue. The conclusion is that the maximum benefit from a potential backfit remedy would provide a very small reduction in risk (i.e., less than 1 E-06/year).

It should be noted that the analysis contained in the report was narrowly focused on the backfil question under review by the Appeal Review Board and is intended to provide additional context and insights to the Board. As such, other applications of this information may not be appropriate unless this limitation is recognized.

Please let me know if you need any additional information or if you would like a briefing.

Regards Richard P. Correia, P.E Director, Division a{ Risk Anah1sis Of£ice al Nuclear Regula.tonJ Research U.S.NRC 2 From: Sent: To: Cc:

Subject:

Corre i a. Ri c hard Fr i day. August 12 , 2016 9: 34 AM Holahan. Gary; West. S te v en; S c arbrough. Thomas; S pencer. Michael; Clark, Theresa Weber , M i chael; Hackett. Edw i n; Thaggard , Mark; Coyne. Kevin Re: Memorandum From: V. McCree to G. Holahan re: Charter for Backfit Appeal Review Panel Assoc i ated w ith B yr on and Braidwood Compliance w i th 10 CFR 50.34(8), GDC 15, GDC 21 , GDC 2 9 , and the Li c ensing Bas i s Your welcome Gary and please let us know if we can support in any way Rich Richard Correia, P.E. Director, Divi s ion of Risk Anal ys i s Office of Nuclear Regulator y Research US !\RC On: 11 August 2016 18: 20, "H~llahan. Gar y" <Gar y.H o lahan Q L}nn.:.gov> wrote: Thanks from me also. Rich. Looks like we will be study i ng the report f o r a w h i le. Gary From: West, Steven Sent: Thursday, August 11, 2016 6: 12 PM To: Correia, Richard <Ri c hard.Correia@nr c.g o v>; Holahan , Gary <Gary.H o lahan@nr c.gov>; S c arbrough, Thoma s <Thomas.Scarbrough@nrc

.gov>; Spencer , Michael <Michael.Spencer@nrc.gov>

Clark , Theresa <Theresa.Clark@nrc.gov>

Cc: Weber, Michael <Michael.Weber@nrc.gov

>; Hackett , E dw i n <Edw i n.H ac ket t@nr c.gov>; Thaggard, Mark <Mark.Thaggard@nrc.gov>;

Coyne, Kevin <Kevin.Coyn e@nrc.gov>

Subject:

RE: Memorandum From: V. McCree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood C o mplian c e with 10 CFR 50.34 (8), G DC 1 5 , GDC 2 1, GDC 29, a nd the Li c ensing Basis Thanks. Rich. This he!ps answer an i mportant q u est ion and w i ll be very helpful to the panel. Please pass on my sincere thanks to all of the c ont r i but o r s. Steve Steven West, Deputy Dire c tor Office of Nuclear Security and Incident Resp o nse U.S. Nuclear Regul a tory C o mm is s io n 301-287-3734 Steven.West@nr c.go v From: Correia, Richard Sent: Thursday, August 11, 2016 5:54 PM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

West, Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>;

Clark, Theresa <Theresa.Clark@nrc.gov>

Cc: Weber, Michael <Michael.Weber@nrc.gov>;

Hackett, Edwin <Edwin.Hackett@nrc.gov>;

Thaggard, Mark <Mark.Thaggard@nrc.gov>;

Coyne, Kevin <Kevin.Coyne@nrc.gov>

Subject:

Memorandum From: V. McCree to G. Holahan re: Charter for Backfit Appeal Review Panel Associated with Byron and Braidwood Compliance with 10 CFR S0.34(B), GDC 1S, GDC 21, GDC 29, and the Licensing Basis Importance:

High Gary et al., The attached risk assessment report addresses the Byron/Braidwood backit issue. The conclusion is that the maximum benefit from a potential backfit remedy would provide a very small reduction in risk (Le .. less than 1 E-06/year).

It should be noted that the analysis contained in the report was narrowly focused on the backfit question under review by the Appeal Review Board and is intended to provide additional context and insights to the Board. As such, other applications of this information may not be appropriate unless this limitation is recognized.

Please let me know if you need any additional information or if you would like a briefing.

Regards Richard P. Correid, P.E Director.

Division of Risk AndhJsis OH ice 0£ Nuclear Rc5\.1Iaton1 Research U.S.NRC 2

Subject:

location:

Start: End: Recurrence

Meeting Status: Organizer:

Required Attendees:

back fi t appea l pane l meet i ng EDO-OWFN-1 7 Hl4-14p Wed 08/1 7/2 0 16 8: 30 A M Wed 08/17/201610: 00 AM (non e) Accepted Clark , Th e r esa Holahan , Gary; Wes t , S t e v en; S carbrough. Th omas; Spencer , Michael Steve's conference session is Tuesday, 10: 30-1 2:00 , so I'm hoping this t i me will work out well. Steve, if you give me a number, we c an call you. I'm guessing this meeting will focus on comment r esponse , discussion of the RES input, and other final items. Thanks, Theresa From: Sent: To: Cc:

Subject:

Thanks, Steve. -----Original From: West, Steven Holahan. Gary Wednesday , August 1 7 , 2016 1:42 P M We s t , S te v en; Cl a r k , The r e s a Sca rbr o ugh. Thomas; Sp en c er. M ic hael R E: Panel repo rt c omme n ts Sent: Wednesday, August 17 , 2016 11: 47 AM To: Clark. Theresa <Theresa.Clark@nrc.gov> Cc: Holahan, Gary <Gary.Holahan@nrc.gov>

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Spencer, Michael <Michael.Spencer@nr c.gov>; West , Steven <Steven.West@nrc.gov

>

Subject:

Panel report comments I'm going to send my comments i n chunks. Here are my commen t s on sect i on 1 and a proposal for a new section 2. Steve From: Holahan , Gary Sent: Wednesday. August 17. 2016 2: 45 PM To:

Subject:

Clarie , Theresa; Spencer. Michael; West. Steven; Scarbrough.

Thomas RE: Containment Contaminat i on Argument Excellent stuff From: Clark, Theresa Sent: Wednesday, August 17, 2016 2: 01 PM To: Spencer, Michael <Michael.Spencer@nrc.gov>

Holahan, Gary <Gary.Holahan@nrc.gov>;

West , Steven <Steven.West@nrc.gov>; Scarbrough, Thomas

<Thomas.Scarbrough@nrc.gov>

Subject:

RE: Containment Contamination Argument Search of FSAR stuff. .. see red for most interesting.

Sorry this is sort of stream of consciousness at the moment. Re standard conformance:

Braidwood 2004 FSAR submittal , but most pages dated December 2002: ML051660219

• P. 15.5-3, Section 15.5.1.2 on IOECCS: " American Nuclear Society standard 51.1/Nl8.2

-1973 (Reference

2) describes example 15 of a condition II event as a "minor reactor coolant system leak which would not prevent orderly reactor shutdown and cooldown assuming makeup is provided by normal makeup systems only." I n Reference 2, normal makeup systems are defined as those systems normally used to maintain reactor coolant inventory under respective conditions of startup , hot standby, power operation, or cooldown, using onsite power. Since the cause of the water relief is the ECCS flow, the magnitude of the leak will be less than or equivalent to that of the ECCS (i.e., operation of the ECCS maintains RCS inventory during the postulated event and establishes the magnitude of the subject leak). Therefore, the above example of a Condition II event is met."

• P. Al.77-1 (dated December 1992): N18.2 is ment io ned in a discussion of RG 1.77 and control rod ejection accidents (that they are a faulted condition as defined in N18.2 ).

• P. 15.0-13 , Section 15.0.8 on p l ant systems and co mponents for accident mitigation: "In determining which systems are necessary to mitigate t he effects of these postulated events , the classification system of ANS1-N18.2-1973 is utilized."

• P. 15.4-13 , Section 15.4.3.l on RCCA misoperation

" Thus , consistent with the philosophy and format of ANSI N18.2 , the event is classified as a Cond i t i on I ll event. By definition "Condition 111 occurrences include incidents, any one of which may occur during the lifetime of a particular plant," and "shall not cause more than a small fraction of fuel elements in the reactor to be damaged ... "" Braidwood 2000 FSAR is only on CD i n the File Center. so I can go get it. R e 50.59s: Braidwood 2002 50.59 report (ML023610638)

-publ icly ava il ab le

• Part 1 of 2, p.129*130 of PDF , effective date 7/11/00: UFSAR chang e package #DRP 8-190 to the Byron/Braidwood UFSAR revised the description in Chapter 15 , Section 15.5.1 "Inadvertent Operation of Emergency Core Cooling System During Power Operations" to remove statements that operator action will be taken to manually open the Pressurizer Power Operated Relief Valves (PORVs). The transient description will be revised to indicate that if the Pressurizer POR Vs are not available, the Pressurizer Safety Relief Valves ( PS RVs) will lift to relieve pressure initially re l easing steam followed by subcooJed water. The existing discussion of the Pressurizer Overfill case will be deleted.

• Part 2 of 2, p.105-106 of PDF, dated 2002: UFSAR Change Package #DRP 9-075 revises the evaluation methodology for the Loss Of Offsite Power (LOOP) event (UFSAR Section 15.2.6) to incorporate water relief through the Pressurizer Safety Valves. This DRP is applicable to Byron and Braidwood Stations Units 1 and 2 .... An additional evaluation was performed that concluded the Safety Valves will not be damaged by the water relief (Westinghouse letter LTR-SEE-01-287)

.... This activity is not considered a departure from a method of evaluation described in the UFSAR because the new methodology (Water relief through the Pressurizer Safety Valves) has been approved by the NRC for a similar event for Byron and Braidwood Stations as part of the Power Uprate Safety Evaluation Report. Parallel Byron 2003 50.59 report (ML031631016) -publicly available

• p.120-121, effective date 12/22/00:

This purpose of this UFSAR change was to revise the description in Chapter 15 Section 15.5.1, "Inadvertent Operation of Emergency Core Cooling System During Power Operations", to remove statements that operator action will be taken to manually open the pressurizer power operated relief valves (PORVs). The transient description is revised to indicate that if the pressurizer PORVs are not available to open to relieve pressure then the pressurizer safety relief valves {PSRVs) will lift to relieve pressure initially releasing steam followed by subcooled water to mitigate the pressurizer overfill portion of the transient.

The effect of the proposed activity will be an updated licensing basis and an updated operations procedure that will reflect the updated licensing basis .... Utilizing the relief valves may result in some degradation and the possibility that the valves may not fully reseat. The probability of the relief valves failing open due to water service application was previously evaluated in the SER for NUREG-073 7, Item 11.D. l. Thus, the change is bounded by the previously evaluated SER and does not increase the probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety .... For analysis purposes, the PORVs are assumed to not be available for mitigation of the inadvertent operation of ECCS during power operation accident.

However, current Technical Specifications requires that "Each PORV and associated block valve shall be OPERABLE" during Modes 1, 2, and 3 (LCD 3.4.11)."

• p.136-137, effective date 7 / 11/00: same topic as 1 §! Braidwood item

• p.161-162, dated in 2002: same topic as 2"d Braidwood item My earlier notes from 50.59s on microfiche-I can go print -these were from the timeframe when PORVs were going to be credited.

• 3/18/94 -(78728:302) change M6-1/2-88-003

-safety-related power to safety-related relays for PORVs to enable manual control during a loss of offsite power

• 3/31/97 (92355:157)

-draft revision package 6-013 -reanalysis of IOECCS, conservative analysis of overfill scenario, remains isolable when ECCS terminated, PORVs allow relief and prevent pressurizer from filling ( 1 PORV adequate);

DNB limits met; water through safeties precluded by relief through PORVs

• 3/31/99 -(A7530:247) change GG-98-0167

-changes to TRM Section 3.4 on Reactor Coolant Systems, justification for automatic PORV actuation to mitigate pressurizer overfill during spurious SI at power Other documents I came across:

• 2004 version ofTechnical Requirements Manual (similar format to TS but not part of license) has TLCO 3.4.d saying one PORV must be unisolated and capable of responding in automatic, or the plant must shut down in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. (ML051660238, p.151 of PDF)-Same in 2014 submittal (ML14363A504)

• 2004 version of TS bases talks about PO RVs and PSVs in the discussion of pressurizer pressure limits (ML051660226, p.35-36), then says this on p.181: HThe Pressurizer Water level-High trip Function provides a backup signal for the Pressurizer Pressure-High trlp and also provides protection against water relief through the pressurizer safety valves. These valves are designed to pass steam in order to achieve their design energy removal rate. A reactor trip is actuated prior to the pressurizer becoming water solid." The pressurizer and PSV /PORV specific items start on p .385 of the PDF. From: Spencer, Michael Sent: Wednesday, August 17, 201611:21 AM 2 To: Holahan, Gary <Gary.Holahan@nrc.gov>;

West, Steven <~teven.West@nrc.gov>;

Scarbrough, Thomas <Thomas. Sea rbrough@nrc.gov>;

Clark, Theresa <Theresa.

C la rk@nrc.gov>

Subject:

Containment Contamination Argument All, Section 3.1.2.2 of the 2015 Backfit states: The licensee has not addressed the questions of how long it would take to clean up a contaminated containment, and whether the time required for completing the cleanup effort and repairing or replacing any damaged PSVs could be long enough to delay the plant's return to operation beyond the short period that is implied in the UFSAR, Chapter 15.5.1.3, definition of Condition II events. Therefore, the "short period" standard is "implied" in UFSAR Section 15.5.1.3.

The Backfit doesn't mention any specific revision of the UFSAR, so I assume it is the current one. This makes sense because it is the current FSAR revision that is currently applicable to the licensee.

The Backflt doesn't raise the issue of an inappropriate 50.59 change, and if there were such an inappropriate change, this would be an enforcement matter. not a backfit matter. Therefore.

although we discussed the 2000 FSAR, I looked at the 2015 FSAR. I looked at the 2015 UFSAR for Byron and Braidwood.

We talked about the 2000 version, but on further reflection, I think the 2015 version is the one to examine because the ANS standard is not a requirement and could only be a current applicable standard for Byron and Braidwood to the extent discussed in the latest FSAR. The existing or appropriateness of previous 50.59 changes is a separate matter. looking at the 2015 FSAR, I found no evidence in Chapter 1 (which has an incorporated by reference (IBR) section) or in Chapter 15 that the ANS standard is IBR'd. Even so, it is possible that somewhere in the 758 page Chapter 15. there is a statement along the lines of "Activity X is accomplished in accordance with the ANS standard," which would import the portions of the ANS standard applicable to Activity X. Still. the Backfit doesn't reference the ANBS standard directly, but instead references FSAR Section 15.5.1.3.

That FSAR section in its entirety is as follows: 15.5.1.3 Radiological Consequences There are only minimal radiological consequences associated with inadvertent ECCS operation.

The reactor trip causes a turbine trip and heat is removed from the secondary system through the steam generator power relief valves or safety valves. Since no fuel damage is postulated to occur for this transient.

the radiological consequences associated with an atmospheric steam release from this event would be less severe than the steamline break event analyzed in Subsection 15.1.5.3.

Water relief from the pressurizer PORVs and safeties may result in overpressurization of the pressurizer relief tank (PRT), breaching the rupture disk and spilling contaminated fluid into containment.

The radiological releases (offsite doses) resulting from breaking the PRT rupture disk are limited by isolation of the containment.

Maybe engineers can read more into this than I can, but I see nothing implied here that implies a short period for the plant's return to operation.

Michael Michael Spencer Senior Attorney U.S. Nuclear Regulatory Commission Office of the General Counsel Office: 015-A18 3 Mail Stop: 016-F3 Washington, DC 20555-0001 Phone: 301-287-9115 Fax: 301-415-3725 Michael. $pencer@nrc.gov 4

From: Sent: To: Cc:

Subject:

Gary, Sc arbrough. T homas Thursday , A u g u s t 18 , 20 16 11: 1 5 AM H olaha n. Gary West , Steven; Spen c er , Michael; Clark, Th e resa RE: THE R E PORT Thi s af terno o n , 1 plan to se n d t o the P anel a markup o f the report inco rpor ating my assignments from yesterday's meeting. Thanks. Tom From: Holahan , Gary Sent: Thursday , August 18 , 201611:11 AM To: Clark, Theresa <Theresa.Cl ark@nrc.gov

> Cc: West, Steven ;

Scarbrough , Thomas <Thoma s.Scarbrough@nrc.gov>

Spencer, Micha e l <Mi c hael.5pen ce r@n rc.gov>

Subject:

THE REPORT There sa , I'm OK with Steve*s edits. Can we discuss exactly what pie c es are needed to get to a fin a l-fi na l report? Gary From: Sent: To:

Subject:

Clark , T he resa Thursday. A ugust 1 8, 20 16 6: 37 PM Spence r , Mi ch ael Re: 2016 Backfit Pa ne l Tom discussion of NRR issues 2016 08 18 Gary MAS.d ocx Thanks, I'll feed them in tomorrow.

On: 18 August 2016 18:30, "S pencer , Michael" <M i chael.S pen ce r@nrc.gov>

wrote: My comments on top of Gary's.

From: Sent: To:

Subject:

Thankst I'm headed back in ... From: Spencer. Michael Cl a rk , Th e res a Friday. August 19. 2016 12:4 4 PM S p encer , M i c hael RE: I'm o u t of the d o c u me n t Sent: Friday, Augu s t 19, 2016 12: 4 0 PM To: Clark , The resa <lh ere sa.C l ark@nrc.go v>

Subject:

I'm out of the document From: Sent: To:

Subject:

Holahan , Gary Friday , August 19. 2016 4:36 PM Clark , Theresa; West , Steven; Scarbrough , Thomas; Spencer, M ic hael Re: cu rrent memo/report fi l es Thanks Theresa ... I'm following the edits. Looks like it getti n g\ cry close. I'm just seeing a few words I'd like to edit... or think about Gary On: 19 August 2016 15:29 , "Clark. Theresa" <Thercsa.Clark~', nrc.gov> wrote: Hi all -I'm still working through the report file (m ade i t to the pink highlight on p.29) but I know Steve wanted to bring a copy on the plane so I'm sendi ng them now j u st in case. Before yo u (likely) start work on Monday, you'll have updated version s of the files that sh ou ld be good for final com m ents a nd infor ma l concurrence. We'll do formal concu rr ence and signature next week. Th ese versions include everyone's edits/comments.

com b i n ed with my editing. The most s ignifi ca nt cha ng es I made were some restructuring in 3.12 (fo r mer 2 .12) and the add i tion of a new short section 2 per Steve's suggestion.

I didn't track them because the track i ng was getting out of hand , and a t this po int we might do best to do a clean read anyway. (I can co nstruc t compare files if anyone really wants them.) Thanks! More to come! Theresa Valentine Clark Executive Technical Assistant (Reactors)

U.S. Nuclear Regulatory Commission Theresa.Clark@nrc

.gov I 301-415-4048 I 0-16E22 From: Sent: To:

Subject:

Clark , Theresa Fr i da y , August 1 9. 2016 5:22 PM Spencer, M ic hael; H olah a n , Gary; West Steven; Scarbrough, Thomas Re: Backfit Appea l Pan el Report (MA STER) -2016-08-19 MAS.docx Thanks much. I'll incorpo rate and resend. On: l 9 August 2016 17: 16 , "Spencer , Michael" <Michael.Spencer

@nrc.gov> wrote: I have some comments through appendix A on the l atest version d i str i buted this afternoon.

I think we are getting pretty close. Michael From: Sent: To:

Subject:

Clark , Theresa Sunda y, August 21 , 20 16 8: 17 AM West , St e ve n; H o l ahan. Gary; Scarbrough. T homas; Spencer. Michael Re: RE VIEW: i nfor ma l conc u rrence version of p anel report Thanks much. Looking forwa rd to you r comment s. Agree th at it'll probably be publi c ... Th at's o ne o f my rema inin g conce rn s. the few n o n-public d oc uments we referenced. W c can discuss next week. Wh en d ocs bu si n ess d ose on a Sunday?:) On: 21 August 2016 07: 20 , "Wci;t. Steven" <Steven. Wcst (l£n r c.g o v> \\.T Oie: Thank s Theresa. J've been reviewing F riday's version. A bout 80 pe rc ent completed.

I have some corr ections and editorial suggestions.

I expect to be done by COB today. I think I'll a l so have a recommended addition to the memo re RIS 2005*29 and it's revision.

I'll se nd to all when comp let ed. Did we decide that we don't need to address w h y the prev ious appeal review panel got this wrong? From the UWC and NSIAC meeti ngs last week , there i s heightened industry interest in where we are going to come out on this. We should plan on our report be i ng made publ i cly avai l able. Steve -*-*** ** Origi na I Message ******** From: "C lark, Theresa" <Theresa.Clark@nrc.gov>

Date: Sun, August 21 , 2016 12:06 AM *0400 To: "Holahan, Gary" <Gary.Holahan

@nrc.gov>, "West, Steven" <Steven.West@nrc.gov>, "Scarbrough, Thomas" <Thoma s.Scarbrough@nrc.gov>, "S pence r, Mi c ha e l" < M i chael.Spencer@nrc.gov>

Subject:

REVIEW: informal conc urr ence ve r sion of panel r epo rt Hi all-attached are the cove r memo (n o change since th e l a s t version, I think) and report (both clean and with changes tracked to th e last version I se nt-no t since the beg i nning). I i ncorporated the e dits that Mi chae l sent F riday. I r ec ommend that you guys r ead these a n d send any r emaining edi t s/comments by mid-day Tuesday-consider this inform al concurrence.

Then 1 ca n g iv e another l ook before we h a v e the meet ing with Vic. S hortly th e reafter I as s um e w e would be able to sign an official copy. (Somew he re i n t here I w i ll ask Patt i to make a co ncurrence package.)

Th an k s! Theresa Valentine Clark Executive Technical Ass i stant (R ea ctors) U.S. Nuclear Regulatory Commiss io n Ther esa.C lark@nrc.gov \ 301*4 1 5*4 04 8 I 0*1 6E22 From: Sent: To: Cc:

Subject:

Cla rk. Theresa Sunday , August 2 1. 20 16 9:02 PM West S t even; Holahan , Gary Spencer , Michae l; Sca rbr o u g h , T homas Re: M y commen t s on Friday's clean master I'll set something up in the morning (and i ncorporat e your ~ommc n ts). Tuesday sho uld work. On: 21 August 2016 19:3 5, "West, Steve n" <Stcven.Wcst

(!L.nr c.gov> wrot e: Any thou g hl s o n mce1ing again before Wed'.'

From: Sent: To:

Subject:

Holahan. Gary Monday. Augus t 22. 2016 7: 17 PM Spencer , M i chae l; West, Steven: Scarbrough , Thomas; Cl ark , Theresa RE: Ba ck fi t Appeal Panel Report (M ASTER)

• 20 16-08-22 R2 -MAS I just added my comments to Tom*s. Gary From: Spencer , Michael Sent: Monday, August 22, 2016 6:19 PM To: Holahan, Gary <Gary.Holahan@nrc

.gov>; West , Ste v en ; Scarbrough, Thomas ; Clark , Theresa <The r esa.C l ark@nrc.gov>

Subject:

Backfit Appeal Panel Report (MASTER) -2016-08-22 R2 -MAS Ari, attached are my comments on the document Ther esa e mai l ed out 20 minutes ago. I incorporated all of Steve's/Tom's/Theresa

's edits , so a n y edits i n the attached are mine. Michael From: Sent: To:

Subject:

C l ark. Theresa Tuesda y , August 23. 20 16 7: 04 AM Spence r. Michael; Holahan. Gary; West Steven; Scarbrough, Thomas RE: Bac\cfit A pp eal P anel Report (MASTER)

• 2016-08-22 R2 -MAS Thank s-I got all of these in the ma ster and will bring copies (including any other edits sent in the next coup l e of hours) to our meeting for discussion. From: Spencer, Michael Sent: Monday, August 22, 2016 6:19 PM To: Holahan , Gary <Gary.Holahan@nrc.gov>; West, Steven <Steven.West@nrc.gov>;

Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Clark, Theresa <The resa.Cla rk@nrc.gov>

Subject:

Backfit Appeal Panel Report (MAS TER) -20 1 6-08-22 R2

• MAS All, attached are my comments on the docume n t Theresa emailed out 20 minutes ago. I incorporated all of Steve's/Tom's/Theresa's edits, so any edits in the attached are mine. Michael From: Sent: To: Cc:

Subject:

Clark , Theresa Tuesday, August 23 , 2016 9:25 AM West , Steven Holahan , Gary; Scarbrough , Thomas; Spencer. Michael RE: Comments on NRR appea l review Thanks much-got these in, and working on another ite m just discussed with Gary {we'll talk about it at 10:00). Also finishing some cleanup items. I have the abbreviations done©. From: West, Steven Sent: Tuesday, August 23, 2016 8:02 AM To: Clark, Theresa <Theresa.Clark@nrc.gov>

Cc: Holahan, Gary <Gary.Holahan@nrc.gov

>; Scarbrough, Thomas <Thomas.Scarbrough@nrc.gov>;

Spencer, Michael <Michael.Spencer@nrc.gov>

Subject:

Comments on NRR appeal review Theresa, This version includes the changes I added to try to address my comment about the NRR appeal review. These changes are on pages 2 through 5. What I don't know is if the NRR review panel's report is publically available or not. If not, we may not want to mention it in this report as I suggested. And, if we don't mention it, we would need to revise some of my language to only refer to the l etter back to the licensee.

Steve Steven West , Deputy Director Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 301-287-3734 Steven. West@nrc.gov

Subject:

location:

Start: End: Recurrence

Meeting Status: Organizer:

Required Attendees: ba c kfit appea l panel meeting EDO-OWFN-l 7 Hl4-1 4 p Tu e 0 8/23/2016 10: 00 AM T u e 08/23/2016 11:00 AM (non e) Accep t e d C l ark. The re sa H o l a h an. Gary; Wes t. Steven: Scarbro ug h. Thomas: S pencer, Michael A s d isc us s ed via em a i l , to p rep for th e mee ti ng wi th Vi c a n d understand any other remaining items.

From: Sent: To:

Subject:

Clark , Theresa Tuesday , Augus t 23 , 2016 1:05 PM S pe n cer. Michae l Re: Spencer Comments on Backfit Appea l Report References 23-16.docx Thank you! I appreciate the extra set of eyes. On: 23 Au!,'USt 2016 1 3:03. "Spencer, Michael" <Michac l.Spcnce r (t~n r c.gov> wrote: Theresa, I did a typo review of the ref erences and abbreviations and have a few com ments, attached, on the references. Michael

Subject:

Location:

Start: End: Re c urrence: Meeting Status: Organizer:

Required Attendees: Optional Attendees: Backf it A p peal P an e l Meet i ng 0-1784 Wed 08/24/20 1 6 1 1:00 AM Wed 08/24/2016 11: 30 AM (none) Accep t e d H o l a h a n , Gary West, Steven; Scarbrough , T homas; Spencer, Michael; Mccree, Victor; Clar k, T h e r esa Johnson , Micha e l; Confe r enceRoom01784 R e source Sc h e dul ed b y P sproge r is 8/11/16 POC: Th eresa C l a rk _J REQUE S T: bad:fit apptaJ panel ...

From: Sent: To: Cc:

Subject:

Patti , (\ark , Theresa Thursday , August 11 , 2016 1: 04 PM Sprogeris. Patricia Hol ahan , Gary; West. Steven: S c arbrough , Thomas; Spen c er, Michael REQUEST: back fi t appea l panel meeting w/ Vic Can you please arrange a meeting for the backfit appea l panel (Gary Holahan, Steve West, Torn Scarbrough, and Michael Spencer) with Vic? Mike may also wish to attend. The week of August 22 would be ideal, perhaps 11am 8/24 for half an hour if Gary and Steve can make that work (others are free). Otherwise, please work your magic to find a time. T hanks! Theresa Valentine Clark Executive Technical Assistant (Reactors)

U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.gov I 301-415-4048 I 0-16E22 From: Sprogeri s , Pa tricia Sent: Wednesday , August 24. 2016 1: 43 PM Cc:

Subject:

Holahan. Ga ry; We st. Ste v e n; Sca r brough. Thomas; Spencer, Michael; Cla rk, T heresa FW: Backfit Appeal R eview P anel F ind i n gs Associated with B yro n & Braidwood I am so so rr y, l forgot to put the cc's in h cfo r c hitting se nd. The package ha s b een di s patched per hclow. Thank you, Patti From: Sprogeris, Patricia Sent: Wednesday , August 24. 2016 1: 41 PM To: RidsNrrOd Resource <RidsNrrOd

.Resource@nrc.gov>

Cor r e i a, Richard <Richard.Correia@nrc.gov>;

Mizuno, Geary <Gea ry.Mizuno@nr c.gov>; l ewis, Rob er t <Ro bert.le wis@nrc.go v>; McGinty , Tim <Tim.Mc G inty@n r c.gov>; RidsNroOd Resource <RidsNroOd.Resource@nrc.gov>;

Johnson , Michae l <Mic hael.Jo hnson@nrc.gov>; Lubinski, John <John.lubinski@nrc.gov>;

Mayfield , M i chael <Mi c hael.Ma yfield@nrc.gov

>; Tracy, Glenn <Glenn.Tracy@nrc.gov>;

Rid sResO d Resource <R i d s Re sO d.Resource@nrc

.go v>; R i d s O gcMailCenter Resource <RidsOgcMailCenter

.R eso ur ce@nrc.gov>

Subject:

Backfit Appeal Review Panel Find in gs Associated with Byron & Braidwood Date: From: Augu s t 24. 2016 Gary \1. Holahan K. Steven We s t Thomas G. Scarhrough 7vtichacl A. Spcni.:cr Theresa Valent ine Cla rk Yicw ADAMS P 8 Properties

\.1Ll92 36Al9~ Qnc11._ADA\i1~

P[J_>a~~a~Bi!c.:kfit A iwcal R c,*ic w Pa,~l F i nd i1_1gs fJbT<.!.11 and B_raidwoo!l))

Thank you. Patti Patti Spro g e ri s Assistant to Michael R. Johnson Office of the Executive Director for Operat i ons 301*41S-1713 Th i s package , and the five docum en ts listed b e low , which are it s contents , a r e publicly a v ailable in ADAMS: ML16243A067 ML16236A202 ML16236A208 ML16214A199 ML16173A311 HES1 1 AV AILAHLE COPY From: Sent: To:

Subject:

Th anks. Tom From: Hol ahan, Gary Scarbrough , Thomas Thursday. September 08 , 2016 6: 27 AM Holahan , Gary; West. Ste v e n; Clark , Theresa; Spencer, Michael RE: NRR Perspe c tives O ED O Bacldit Panel Findings.docx -Sent from L__J Sent: Wednesday, September 07 , 2016 11:11 PM To: West. Steven <Steven.West@nrc.gov>;

Scarbrough , Thoma s <Thomas.Scarbrough@nrc.gov>;

Clark, Theresa <Theresa.Clark@

nr c.gov>; Spen c e r , Michael <Michael.Spe n c er@nrc.gov>

Subject:

Fwd: NRR Perspectives OEDO Backfit Pane( Findings.docx -Sen t from MaaS360 FYI let's wait for Vi<:'s dire c tion heforc an y furt h er review or in te ra c tion with f',;RR. I feel good ahout the review we did and t he report t oo .. Gary From: "McCree. Victor" <.Yictor.;vlc('rec lli_nrc.go\> r bJ(6)

Subject:

Re: NRR Perspectives OEDO B ac kfi t Pa nel Findings.docx

-Sent from._ ___ __. Date: 07 September 2016 18:57 To: "Holahan, Gary" <Oar y) l oh.1haQ (!_{_nr~o~:> Thanks Gary. Please (re)encourage a ddr es s ee s to not s hare this resp o nse further. As you know, I did not solicit J\RR's most rt:ccnt respon s e and. whi le I will ack n owledge it in my final deci s ion. I want to ensure we remain in process (to the extent practical)

Vic On: 07 September 2016 16:33, "Holahan , Gary" <Qa_Q.Hll l ahan w nrc.go~> wrote: Vic, You may find this useful. Attached are Tom Scarborough

's writte n responses/answe rs to the latest NRR e-mail on the panel's report. They have only been s har ed with the panel. .. not NRR. Both Steve West and I agree that Tom has done a good Job in providing responses and context. Although you have not asked the pa n el to re vi ew or respond t o NRR's comments, and we have not done so formally, you may find Tom*s thoughts useful. If we can provide any additional suppo rt to you r rev i ew of the report. please Jet me know. Gary BK~1' AVAUABLE COPY From: Sca rbr ough, Thomas Sent: Wednesday, Septembe r 07, 2016 2:48 PM To: Holahan, Gary <Gary.Holahan@nr c.gov>; West , Ste v en <Steven.West@nrc.gov>;

Clark, Theresa <Ther esa.Clark@nr c.go v>; Spencer , Michael <Michael.Spencer@nrc

.g ov> l (b)(S)

Subject:

RE: NRR Perspectives OEDO Ba ck fit Panel Find i n gs.docx -Sent from ._ __ __, For your consideration , atta c hed is my br i ef response t o the spe ci f i c i tems in the NRR Per spectives document.

Thanks. Tom From: Holahan , Gary Sent: Tuesday, September 06 , 2016 8: 46 AM To: West, Steven <Steven.We..il@_nrc.gov>; Clark , Theresa <Theresa.Clark@nr c.gov>; Scarbrough, Thomas <Thom as.Scarbrough@n re .gov>; Spence r , .Michae I <Michae l.Spencerln'lnrc~oH>

-* ----* (b)(6)

Subject:

RE: NRR Perspectives OEDO Ba ck fit Panel F i nding s.docx -Sent from ----Thanks , Steve. We will keep you informed if any t h i ng h appens. I do agree with you ... we don't need to be right about everything, NRR does! From: West, Steven Sent: Tuesday, September 06, 2016 8: 39 AM To: Holahan , Gary <Gary.Holahan@nrc.gov

>; C l ark , Th eresa <Theresa.Clark@nrc.gov>;

Scarbro ugh, Thomas <T homas.Sca rbrough(a)nrc.gov>;

Spen c er , Michael <M ic hae l.Spen c er n r c. v>

Subject:

Re: NRR Per sp ective s OEDO Ba ck f it Panel F i ndi n gs.docx -Sent fro (bl(6 l -----rml (b)(6) !and not available.

Please pr oceed without me. I remain comfortable with our review, our co nclu sio n s and our recommendations. A few th o ughts: A s urpri si ngly weak and unin sp ired def ense of the backfit. A n equa lly humdrum critique of the Panel's review and conclus i ons. It may be better for Michael to address t h is, but i t seems to me that one need find only one f atal flaw with the backfit to overturn it. The staffs argument that it considered numerous issues (as did t he Panel) doesn't diminish the Panel's findings.

The staff and the panel seem to agree that not e v eryth i ng (guidance , interpre tat ions, safety evaluations, etc.) has been clearly and consistently established and do c umented ov er time. We s eem to differ on how n e w interpretations should be promulgated.

Th e backfit and the two st aff responses to the Panel's review c o n firm the need for additional backfitting guidance and training.

Steve --------O rig inal Message --------From: " Holahan, Gary" <GfilyJ:jolahan (ci)nre,gQY> Date: Fri, September 02 , 2016 12: 04 PM -0500 To: "Clark, Theresa" <lheresa.Clark

@nrc.g~>, "West , Steven~ , "Scarbrough, Thomas" . "S pe ncer , Michael" <1".'tich ae l.S~nce r~n rc.gov> CC: Mi chae l John son l<b l(6) !'McCree , Victor" <Vict or.McCree@nrc.gov>, "Tracy, G l enn" <G/enn.Tracy@n r c.gov> 2 HES'I' AVAIIAlltE co1*v

Subject:

Re: NRR Perspectives OEDO Backfit Panel Flndings.docx

• Sent fromL___J I agree. [ think the ul tima te decision is up to th e EDO. B oth the panel and ~RR owe him a clear pit:turc of what agreeing wit h '.'JRR o r the panel mean s. L et's d i scuss early next week Gary ----*---*-.. -------On: 02 Sept ember 2016 12:06. "Clark. T heresa" <TI 1 crcsa.C~nrc.g0\ > wrote: FY I. I believe mo s t o f thi s was i n the prc,*io u s se t o f commen t s. I d o n't sec a lot r e la ted to the backlit stan d ar d an<l how these h ave been app li e d in the pa st o r to B-'B. Begin Forw arded Message: From: "Dean Bill" <Bill.Dea1 Va nrc.l!o,*> EJ

Subject:

NRR Pcrspcdi~s *OF.DO Back fi t Panel F indi n gs.docx -S ent from b)(6 l Date: 02 September 2016 1 1 :20 To: "l'ic.\k(r.cc t 1inn.:,~,~" <V(c.\kCn.~~'a nn:.gov>. "John son. \i1i chacl" <\1ic had.Johnson(a me.go,*> Cc: "Holahan.

<, ar y" <~1;!f y.l lolal1_l11_1 (cl n r c.g_l>\*>. "Cl ark. Theresa" <T hen.::sa.C!ark

~nr c.go,*>, "Mc D c1111o u. Brian" < Br i an.\1d)c11n\1tt(a nr c.gO\*>. "Evans. Mil.:hck" <M!c hc1',:.Evans (11 nrc.g~i,:>. "L u bin s k i. Jo h n" <Jo hn. Lu h i1~ki.~c~~v>, "Ross-Lc c. \1aryJ ane" <~arvJant:.Rtiss-Lcc

!a n rc.g ov>. "Taylor. Rohcrt" <Roht:rt.TaYlor 1 a nrc.gt~> Vh.: , md \1ik c Appreciate the opportunity to share with yo u N RR's pcrspcctin:

related to the appeal panel's recommendations.

L no k fo rw ard t o discussing with yo u after your vacation -hop e it is an enjo ya ble one. 3 From: West. St e v en Sent: Thursda y. September

15. 2016 1 0:20 AM To:

Subject:

Clark. The re sa; Holahan. Gary; Scarb r o ugh. Thomas; Spencer, M ichae l R E: backfit appea l d oc ument s s i gned Thank you fo r sharing , Th eresa. Vic's safety and v a l ues messages in his memo to B il! a re especially nice. Steve Steven West. Deputy Director Office of Nucle ar Se c urity and In c i dent R esponse U.S. Nuclear Re gulatory Commission 30 1-287-373 4 Steven. West@nrc.gov From: Clark , Th e re sa Sent: Thursday , September 15 , 2016 10: 00 A M To: Holahan, Gary <Gary.Ho l ah an@nr c.gov>; Wes t , S te v en <Steven.Wes t@nrc.gov>;

Scarbrough, Thomas <Thom as.S ca rb roug h@nrc.g ov>; S p e ncer , Mi c hael <Michae l.Spe n cer@nrc.gov>

Subject:

FW: backfit appeal documents s i gned Goo d morni ng, all! This morning , Vic signed the three documents as soci ated with t he Byron/Braidwood backfit appeal. They are being pro cesse d now, and we e J<pec t that th ey (along wi th the p a n el do cu ment s referenced w i th in) will be made publicly available in ADAMS lat e r to day. Pl ease let me kn ow i f you have a ny quest i ons. Thank s!

• Letter responding to Exelon: ML16243A067

• Letter responding to NEI: M L 1~246 A1 50

• Memo to NRR: ML16246A247 Theresa Valentine Clark EJ<ecutive Technical Assistant (Reac t ors) U.S. Nuclear Regulatory Commission Theresa.Clark@nrc.

gov I 30 1-415-4048 I 0-16E22 Pub licly Ava il ab l e in ADAMS From: Sent: To:

Subject:

Bank s , Eleasah Friday. September 1 6. 2016 8: 17 AM RidsNrrMai l Center Resource; R i dsOgcMa i l C enter Re s ource; RidsNroMailCenter Re s ource: R i dsRe s PmdaMai l Re s ource; RidsResOd Re s ource; RidsNmssOd Resource; RidsRgnlMai l C enter Resource; RidsRgn2MailCenter Resource; RidsRgn3Mai1Center Resource; R i dsRgn4Ma i l C enter Resour c e; R i dsNrrDorlLpt3

-2 Resource; RidsNrrPMByron Reso u rce; R i d s NrrPMBra i dwood Res o urce; RidsNrrD s s Re s ource; RidsNrrDe Resource; RidsNrrDpr Resource; RidsNrrDorl Resource; Garmoe, Alex; Keene. Todd; Gody , Tony; Ge n delma n , Adam; Mizu n o. Beth; C orre i a , R i chard; West, Khadijah; Bailey, Marissa; S c arbrough. Th o mas; S pen c er. Mi c hae l; Clark , Theresa Appea l of Backf i t I mposed in Braidwood and Byron Stations (To William Dean, From: V i cto r McCree) Da1e: September

15. 2016 Memorandum To: William M. Dean From: Victor M. McCree

Subject:

Appeal of Ba ckfit Imposed in Bra idwood and Byron Stat i ons (T o: Wi lli am Dean , F rom: Victor McCree) Publicly available in ADAMS View ADAMSP8 Propert i e s \.1 Ll6246A24 7 Qpcn ADAMS P8 OocumctH (Appea l of B a d.fit I mp o s ed i n Bra i dw o od and Byron Station s (To: Willi'!m Dean. [rom: Victor__,_\1crrcc_u From: Sent: To:

Subject:

Date: September 15 , 2016 Memorandum To: J. Bradley From: Victor M. Mccree Banks , Eleasah Fr i da y, September 16 , 20 16 9:07 AM RidsNrrMa i lCenter Resource; R idsOgcMailCen ter Resource; RidsNroMailCenter Re so urce; R i dsRe s PmdaMail Re so ur ce; Rid sResO d Resource; Rid sNmssO d Resour c e; RidsRgnlMailCenter Res o urce; RidsRgn2MailCenter Resource; RidsRgn3MailCenter Re so urce; R i dsRgn4Ma ilCe nter Resource; RidsN r rDorlLpl3-2 Resource; RidsNrrPMByron Resource; R i dsNrrPMBra i dwood Resource; RidsNrrDss Re sourc e; RidsNrrDe Resource; RidsN r rDpr Resource; RidsNrrDorl Resource; Garmoe , Alex; Keene, Todd; Gady, Tony; Gendelman, Adam; M i zuno, Bet h; Correia, R ic hard; West, Khadijah; Bailey, Marissa; Scarbrough , Thomas; Spencer , Michael; Clark , Theresa Backfit Appeal Re view Panel Findings (Byron and Braidwood)

Subject:

Backfit Appeal Review Panel Findings (Byron and Bra i dwood) View ADAMS P8 Properties MLI 6236A 198 Open ADAMS PS Package (Backfit Appeal Review Panel Findings (Byron and Braidwood))

Th i s package , and the fo ll ow i ng documents , wh i ch a r e its contents , are pub l i cly ava il ab l e i n ADAMS: ML16243A067 M L 16236A202 ML16236A208 ML16214A199 ML16173A311 1

from: Sent: To: Cc:

Subject:

Ho laha n , Gary T h u r sday. J uly 1 4. 2 0 16 9:09 AM Spencer , Mi c hael; Cla rk. There s a West , Steven; Scarb r ou g h. Thomas RE: Backfi t panel Meeting Very good, thank you . I'm br i nging a copy to th e pane l mee t in g! from: Spencer , Michael Sent: Thursday, July 14, 2016 9:00 AM To: Holahan, Ga ry <Gary.H ola h a n@nrc.gov>; C lark , The r esa

Cc: West , Steven <Steven.W est@nrc.gov>; Sca rbro ugh , T hom as <Thomas.Scarbrough@nrc.gov>

Subject:

RE: Ba ckfit panel Meeting Let me state this in writing to make i t cl earer and elaborate somewhat on my discussion with Theresa. (b)(!l) Michael From: H o l a h an , Gary Sent: Th ur s day, July 14, 2016 8: 03 AM To: Clark , The resa <Theresa.Clark@n r c.gov>; S penc er , M ic h ae l <Mic ha el.Spence r@nr c.gov> Cc: We st, Steven <Steven.We s t@nrc.gov>; Sca rbr o u gh , Thomas <Thom a s.Scarb r ough@nrc.go v,>

Subject:

RE: Backfit p ane! Me e tin g excellent From: Clark, Th e re sa Sent: Thursday, July 14, 2016 7:45 AM To: Holahan, Gary <Gary.Holahan@nrc.gov>;

Spenc er , Mi c hael <Michael.Spencer@nrc.gov>

Cc: We s t, Steven <Stev en.West@nrc.gov>;

Sca rbrough , Th o ma s <T h omas.S carbr ough@nrc.gov>

Subject:

Re: Backfit panel Meeting Mkhael and I discussed this the other day so I know he's ready for il :). On: 14 July 2016 07:42. " Holaha n. Gary" <Gan .I lolahan'm1 n:.g m > \.\T o te: Michael, (b)(5) Gary 2 From: Sent: To:

Subject:

OK, got it. Thanks. Michael From: Spence r , Micha e l Holahan , Gary Wednesday. August 10 , 2 016 10: 59 AM Spencer. Mi c hael; We s t , Stev en; Sc arbrough , Thomas; Clark , Theresa R E: Exelon Backfit Appea l Pa n el Prelimi n ary Findings FOR COMMENT -dt!t1S l u1\al -tn r e rn ai rJR L U s e O n ly -Sent: Wednesday, August 10 , 2016 10: 23 AM To: Holahan , Gary <Gary.H olahan@n r c.g ov>; West , Ste v en <Steven.West@nrc.gov>

Scarbrough, Thomas <Thomas.Scarbrough@nrc

.gov>; Clark , There s a <Theresa.C lark@nrc.gov>

Subject:

FW: E xelon Ba ckf it Appeal Panel Preliminary F indin gs FOR COMMENT -0 1:40 "On'IV"-OGC's reactor and materials ruterna king {RMR) divis i on has prov i ded its input on the draft preliminary findings. See email below. Michael From: Spencer, Mary Sent: Wednesday, August 10 , 2016 10: 19 AM To: Spence r , Mi c hael <Michael.Spence r@nr c.gov> Cc: Mizuno , Geary <Geary.Miz u no@nrc.gov>

Campbell , T is on <Ti s o n.Campbell@nrc.gov>;

Jones , Bradley <Bradley.Jones@nrc.gov>

Benowitz , Howard <H o ward.Benowitz@nrc.gov>

Gendelman.

Adam <Adam.G e nd e lman@nr c.gov>

Subject:

RE: Exelon Backfit Appeal Panel Preliminary F i ndings FOR COMMENT-6 t1 5 11'.e d c cis i o .. al l .. tc .. :a l ~m 6i lsb!! ....Q.ali.;i.-

Michael. (b)(5) Thanks , Mary M ary B. Spencer As s istan t General Coun s e l for Reactor s and Material s Rulemaking s Office of the Gener a l Counse l US Nuclear Regulatory Comm is s i o n (b)(5) From: Holahan, Gary Sent: Monday , August 01 , 2016 5: 57 PM To: Dean, Bill <Bill.Oean@nrc.gov>; Lubin s ki , John <John.Lubinski@nrc.gov>;

Mcg in ty, Tim <Ti m.McGinty@nrc.gov>;

Ak s tul e wicz, Frank <F rank.Ak stu/ewicz@n r c.go v>; Do a ne , Margaret <Mar garet.Doane@nrc.g ov>; M cd erm ot t, Brian <Brian. McDermott@nrc

.gov>; Bailey , Marissa <Marissa.Bailey@nrc.gov> Cc: Hackett, Edwin <Edwin.Hackett@nrc.gov>;

W est, S te v e n <Stev en.West@nrc.gov>;

Clark, Theresa ; Scarb r o u gh, Thom as ; S pe nce r , Mi c ha e l <Michael.Spencer@nrc

.go v>; E va n s, Miche l e <M i chele.E v an s@nrc.gov>; Williamson, Edward <Edward.William so n@nr c.g o v>; Mizuno, G eary <Gea ry.Mizuno@nrc.gov>

Shu aibi, Mohammed <Mohammed.Shuaibi@nrc

.gov>; M cc ree , Vic tor <V i c t o r.M cC r ee@nrc.gov>;

Johnson, Michael <Michael.Johnson@n rc.gov>; Trac y, Glenn <G l enn.T r a cy@nr c.g ov>; Gody, Tony <Tony.Gody@nrc.gov>

Subject:

Ex elon Ba c kfi t Appeal Panel Preliminary F i nding s FOR COMM E NT-8~8f,e*d e tisi'7ft dl l 11te. 11al 14" e l".l s e Oil l y L (b)(5) J