ML030700055
| ML030700055 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/2003 |
| From: | Dennig R NRC/NRR/DRIP/RORP |
| To: | Bradley B Nuclear Energy Institute |
| Tjader T., NRC/RORP, 415-1187 | |
| References | |
| Download: ML030700055 (29) | |
Text
"V*x UNITED STATES NUCLEAR REGULATORY COMMISSION 0* WASHINGTON, D.C. 20555-0001
'- .. March 7, 2003 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708
SUBJECT:
MARCH 5, 2003:
SUMMARY
OF MEETING WITH RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)
Dear Mr. Bradley:
The purpose of this letter is to transmit the summary of a meeting with the RITSTF. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on March 5, 2003.
Sincerely, Robert L. Dennig, Section Chief Technical Specifications Section Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
Enclosures:
- 1. Meeting Summary
- 2. Attendance List
- 3. Agenda
- 5. Presentation Vugraphs on "STP Risk-Informed Technical Specifications."
- 6. RITSTF Initiative Status cc w/encl: See attached page
March 7, 2003 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 1Street, NW Washington, DC 20006-3708
SUBJECT:
MARCH 5,2003:
SUMMARY
OF MEETING WITH RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)
Dear Mr. Bradley:
The purpose of this letter is to transmit the summary of a meeting with the RITSTF. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on March 5, 2003.
Sincerely,
/RA/
Robert L. Dennig, Section Chief Technical Specifications Section Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
Enclosures:
- 1. Meeting Summary
- 2. Attendance List
- 3. Agenda
- 5. Presentation Vugraphs on "STP Risk-Informed Technical Specifications."
- 6. RITSTF Initiative Status cc w/encl: See attached page DISTRIBUTION:
See next page ADAMS ACCESSION NUMBER:
DOCUMENT NAME: G:\RORP\TSS\TJADER\RITSTF-MTGsum-3-5-03.wpd OFFICE TSS:RORP:DRIP SC:TSSXQ1WJqpIHIP NAME TRTjader - RLDenir_ d\:,l DATE 03/17 /2003 03/1 /2003 OFFI IIAL RECORD COPY
DISTRIBUTION:
ADAMS PUBLIC TSS R/F TSS Staff DMatthews/FGillespie (RidsNrrDrip)
WDBeckner (RidsNrrDdpRorp)
GMHolahan (RidsNrrDssa)
RJBarrett (RidsNrrSpsb)
JZwolinski (RidsNrrDIpm)
JNHannon (RidsNrrDssaSplb)
TRQuay (RidsNrrDipmiqmb)
OGC (RidsOgcRp)
ACRS/ACNW (RidsAcrsAcnwMailCenter)
MI-Wohl (MLW1)
NSaltos (NTS)
MRJohnson (MRJ1)
WScott (WES)
GSShukla (GSS)
FMReinhart (FMR)
AWMarkley (AWM)
SI-Magruder (SLMl)
RFDudley (RFD)
DFThatcher (DFT)
MACaruso (MAC)
MI-Scott (MLS3)
EMMcKenna (EMM)
MACunningham (MAC3)
ASKuritzky (ASK1)
MTMarkley (MTM)
SDAlexander (SDA)
MDrouin (MXD)
MCThadani (MCT)
TAReed (TAR)
SWest (KSW)
Mr. Biff Bradley cc via e-mail:
Mr. Tony Pietrangelo Mr. Rick Hill Nuclear Energy Institute General Electric Nuclear Energy Mr. Biff Bradley Mr. Michael S. Kitlan, Jr.
Nuclear Energy Institute Duke Energy Corporation Mr. Mike Schoppman Mr. Noel Clarkson Nuclear Energy Institute Duke Energy Corporation Mr. Alan Hackerott, Chairman Mr. Donald Hoffman Omaha Public Power District EXCEL Services Corporation Mr. Jim Kenny Mr. Ted Book Pennsylvania Power & Light Company Framatech-ANP Mr. James Andrachek Mr. R. J. Schomaker Westinghouse Electric Company Framatech-ANP Mr. Jack Stringfellow Mr. J. E. Rhoads Southern Nuclear Operating Company Energy Northwest Mr. Donald McCamy Ms. Deann Raleigh Browns Ferry Nuclear Plant Scientech Mr. Ray Schneider Mr. Ken Canavan Westinghouse Electric Company DS&S Mr. Frank Rahn Mr. Sam Chien EPRI SCE Mr. Wayne Harrison Mr. Gary Chung STP SCE-SONGS Mr. Drew Richards Mr. Courtney Smyth STP PSEG Nuclear LLC Mr. Gabe Salamon Mr. Jerry Andre PSEG Nuclear Westinghouse Electric Company
SUMMARY
OF THE MARCH 5,2003, NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE The NRC staff met with the NEI Risk-Informed Technical Specification Task Force (RITSTF) on March 5, 2003, from 8:30 a.m. to 11:30 a.m.z-The meeting attendees are listed in Enclosure 2.
The agenda (Enclosure 3) consisted of discussions of the seven active RITSTF initiatives.
Industry representatives gave presentations on the Combustion Engineering Owners Group (CEOG) and the South Texas -Project (STP) pilots for initiative 4b. Alan Hackerott provided information on the CEOG pilot (Enclosure 4), and Wayne Harrison provided information on the STP pilot (Enclosure 5). The RITSTF provided a summary of the status of the initiatives (Enclosure 6). Following is a brief description of the status of the initiatives in the order in which they were discussed.
Initiative 4b, Risk Informed CTs/AOTs: The NEI RITSTF provided a draft risk management guidance document and the CEOG single system pilot proposal, TSTF-424, on January 21, 2003. The RITSTF will submit the whole-p!ant STP pilot proposal in March 2003. The NRC staff will begin organizing and commencing the review process for the submittals.
Initiative 3, TSTF-359, Modification of mode restraint requirements of LCO 3.0.4 & SR 3.0.4:
The first CLIIP Federal Register Notice was published on August 2, 2002, requesting public comments. Public comments have been received and are being addressed. The staff will publish the final CLIIP Federal Register Notice announcing availability as soon as all issues are resolved, which is expected to be completed in late March 2003. NEI wil be conducting a workshop in the near future for operators and PRA practioners on implementation of initiatives 2 and 3.
Initiative 7, Non-TS support system impact on TS operability determinations: The RITSTF plans to submit TSTF-372, Revision 4, on snubber inoperability, in April 2003. The RITSTF submitted the Initiative 7 TSTF-427 addressing barrier inoperability, on March 4, 2003. The RITSTF will assist the NRC in revising GL 91-18 via a future public workshop.
Initiative 1, TS Actions End States Modifications: The BWR topical SER was issued on September 27, 2002. The BWR TSTF-423 is being developed and will be submitted by the end of June, 2003. The RITSTF submitted a revision to CE TSTF-422 on January 24, 2003, expanding its applicability from a loss of single train to address a loss of LCO function; NRC staff review will commence in the near future.
Initiative 6, Modification of LCO 3.0.3 Actions and Completion Times: A final response to NRC RAIs will be submitted in May 2003. The staff is preparing an SER on the CEOG Initiative 6b/c submittal. The RITSTF plans to submit a comprehensive TSTF-426 in September 2003.
Initiative 5, Relocation of non-safety SRs (5a) and relocation of all SR frequency requirements (5b) out of TS: The RITSTF will develop a Guidance Document on an Initiative 5b methodology and provide it to the NRC in May 2003. The TSS staff plans to meet with OGC in the next month to discuss the initiative 5b concept and ensure they have no legal objection. Limerick has volunteered to be the pilot plant to test the proposed program and procedures. After NRC Enclosure 1
-2 review and acceptance of the Guidance Document, and the results of the pilot plant application are evaluated, the RITSTF will prepare and submit TSTF-425 by December 15, 2003. The RITSTF will submit a TSTF to relocate some SRs under Initiative 5a by September 30, 2003.
Initiative 8a, Remove/Relocate non-safety and non-risk significant systems from TS that do not meet 4 criteria of 10 CFR 50.36: The RITSTF will interface with the NRC in the development of guidance and a methodology, based on NEI 00-04, for the application of the four criteria of 10 CFR 50.36. The RITSTF will develop a white paper on Initiative 8a, outlining the guidance and methodology for implementation in the third quarter of CY 2003.
The next NRC TSS/NEI RITSTF meeting is scheduled for May 15, 2003, at the NRC Headquarters in Rockville, MD.
NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE ATTENDANCE LIST MARCH 5, 2003 NAME AFFILIATION TONY PIETRANGELO NUCLEAR ENERGY INSTITUTE BIFF BRADLEY NUCLEAR ENERGY INSTITUTE DONALD HOFFMAN EXCEL SERVICES ALAN HACKEROTT OPPD FRANK RAHN EPRI JIM ANDRACHEK WESTINGHOUSEJWOG MIKE KITLAN DUKE ENERGY NOEL CLARKSON DUKE ENERGY JACK STRINGFELLOW SOUTHERN NUCLEAR OPERATING COMPANY J. E. DUSTY RHOADS ENERGY NORTHWEST/BWROG WAYNE HARRISON STP NOC DREW RICHARDS STP NOC BOB SCHOMAKER FRAMATOME-ANP RAY SCHNEIDER WESTINGHOUSE PSA BOB DENNIG NRC/NRR/DRIP/RORPITSS BOB TJADER NRC/NRRJDRIP/RORP/TSS KERRI KAVANAGH NRC/NRR/DRIP/RORP/TSS PETER HEARN NRC/NRR/DRIP/RORP/TSS CRAIG HARBUCK NRC/NRR/DRIP/RORP/TSS TOMMY LE NRC/NRR/DRI P/RORP/TSS CARL SCHULTEN NRC/N RR/DRI P/RORP/TSS NICK SALTOS NRC/NRRJDSSA/SPSB MILLARD WOHL NRC/NRRJDSSA/SPSB MARK REINHART NRC/NRR/DSSAISPSB MARK CARUSO NRC/NRRPDSSA/SPSB STEPHEN ALEXANDER NRC/NRRJDIPM/IQMB STU MAGRUDER NRC/NRR/DRIP/RPRP MARY DROUIN NRC/RES/DRAAMPRAB STEVE WEST NRC/NRR/RPRP/RGEB TIM REED NRC/NRR/RPRP/RGEB MOHAN THADANI NRC/NRRJDLPM/LPD1 Enclosure 2
AGENDA TSB/NEI RITSTF Meeting March 5, 2003 from 8:30 AM to 4:00 PM, in O-13B4 o Status of Initiatives "o Initiative 4b, RI Configuration Management CTs/AOTs Integration Plan and Guidance Document CEOG TSTF-424 Industry proposed approaches, pilot presentations o Public Questions and Discussion "o Initiative 3, LCO 3.0.4 & SR 3.0.4 (Mode Restraint) Flexibility Final FRN "o Initiative 7, Non-TS Support System Inoperability Impact on TS System TSTF-372 TSTF-427 "o Initiative 1, End States CEOG TSTF-422 BWROG TSTF-423 "o Initiative 6, LCO 3.0.3 Actions and Completion Times CEOG final submittal and staff SER o Public Questions and Discussion "o Initiative 5, STI Evaluation Methodology "o Initiative 8a, Remove/Relocate non-safety & non-risk significant systems from TS o Public Questions and Discussion o Schedule Next Meeting o Closing Comments Enclosure 3
Flexible AOT and the HPSI Pilot March 2003
Background
- Emphasis on single AOT extensions
- Joint NRC/Industry Global Risk Informed Initiative began in 1998
- initiatives designed to risk inform the ISTS
- goal to allow plant to manage risk and avert unnecessary shutdowns
- Further meld maintenance rule philosophy, and PSA with TS Enclosure 4
The Flexible AOT is a Logical Adjunct to the Maintenance Rule
- The flexible AOT concept was proposed in NRC sponsored meetings in 1998 as initiative 4B to the global risk informed TS revisions Flexible AOTs were desired to let Maintenance Rule Control plant risk and Maintenance:
- Inflexibility of prescriptive TS structure can discourage and complicate some maintenance
- Multiple partial repairs
- parallel vs. series maintenance
- total system Inoperability encouraged
- TS prescriptive actions can be risk adverse
° transition risk -power operation trade off
- Establish consistency with Regulations I.e.. (Maintenance Rule a(4))
- Ties maintenance decisions to plant risk Impact s---- - -
FEATURES of the FLEXIBLE TS AOT
"* Front Stop established by current TS
"* Risk assessment managed by Risk-Informed Technical Specifications Risk Management Guide
- tracked
- limited to small risk increments
- robust a(4) process with shutdown decision process
"* Backstop Time Limit provided for return of system to Operability regardless of low risk level.
"* Accumulated use of backstop AOT monitored and compared to RG 1.174 guidelines
Why a Single Syte Plt?
Example system TS Pilot was selected to incrementally introduce and explore the concept of flexible AOTs
- Flexibility in TSs requires study of programmatic issues
- Single, well-understood system provides a means to explore impact of change in detail OK then, Why HPSI?
- HPSI is a risk important and challenging system.
- However,
- the HPSI System has several low risk states which may challenge operability without significantly impacting risk.
"* degraded pump performance
"* single injection valve inoperability
- HPSI has limited interaction with external event scenarios
- risk can be well quantified
- TS may be implemented by all CE designed PWRs with a technically adequate PRA
- HPSI provides a focused example to test guidance document.
What is in the Report?
. The HPSI TS AOT Pilot Report Includes
- Description of the proposed TS change
- Basis and need for request
- Potential risk impacts over a group of plants with varying HPSI system designs
. comparison of partial inoperabilities valve maintenance examples support system examples
- includes impact of simultaneous maintenance activities
"*Includes LERF estimate and insights
"*Includes insights associated with fire, seismic and transition risks.
The Role of the Guidance Document
" Submitted with Risk-Informed Technical Specifications Risk Management Guide
- Identifies key elements of the process
- recommends risk targets
- recommends tracking altematives
"* The guidance is appropriate for single or multiple system implementation
"* Details to be resolved on implementation and review
'Wi
Closure
" HPSI Pilot helping to resolve industry issues associated with implementation of the Flexible AOT and the associated guidance document
"* The Pilot is a building block in a process to extend flexible AOTs to a wider range of systems.
"* Pilot provides a critical step at consistently integrating Maintenance Rule practices and the TS.
STP Risk-Informed Technical Specifications Benefits of RITS
"* Focus on what is really important to safety
- Eliminates many opportunities for TS 3.0.3
- Would virtually eliminate NOEDs for the SSCs covered by the change
"* Complements Maintenance Rule
- Applies same Configuration Risk Management Program
"* Facilitates on-line maintenance I
Enclosure 5
STP Risk-Informed TS WOG Lead Plant
- Result of NRC-Industry initiative
- STP model will provide opportunity for industry and NRC to develop an acceptable generic format and approach Submittal Schedule
"* Submit "Letter of Intent" with proposed changes in early 2003
- Just a BIG meeting agenda
- Identify and resolve policy issues
- Propose STP as a pilot, specifically for DG-1 122
- Provides opportunity for industry involvement
"* Meet with NRC to resolve major issues
"* Formal License Amendment submittal after comments resolved
"* Final approval in mid to late 2004 2
STP RITS Model Apply the Configuration Risk Management Program to extend allowed outage times for selected LCO Addition of TS 3.13
- Will be called out by the individual TS to which it may be applied
- Allows the application of CRMP as an alternative to the existing allowed outage times ("frontstop" time)
- Incorporates a not-to-exceed "backstop" time of 30 days 5
STP General Concept A broadly applicable TS 3.13 based on incremental risk thresholds determined in the CRMP Consistent with "Risk Management Technical Specifications Risk Management Guide" 3
Draft TS 3.13 ALLOW F DIOUTFAQFrrME JiF TE RM iNATION
- UNrtING CONDI*,t9N FOR 9P-RATIgO 3 13 1 When referred to this opeclllcallon, equipment tott eo boon removed from service or decred Inoperable shag be o valuated for its Impact en plant risk 8nd.llowod outage times determined
... 0 rdingly APPLICAbILrry As required by tho reforeesing speolficatlen Determine that the configuration Is acceptable for Completion Time extenslon beyond the IFront Stop AOT],
Determine that the conliguration Is acceptable for continued oporobon beyond the lFront Stop AOTJwheneveroonliguration changes occur that may affect plant risk.
Restort required Inoperable (subsystem, componontlto OPERABLE status Within the Acceptable Allowed Outage Time Extension or 30 days, whichoverhi shorter Note The 30 day limitation may be applied Individually to each specification for wnich Specllicatlon 3 13 1 has been entered DA Take the ACTION required In the referenoing specification for required action or completion time not met SURVEILLANCE REQUIREMENTS 4 13 1 An raqvired by the refereoalog specfioation Sample Specification PLANT SYSTEMS 314 7.4 ESSFENrTAL COOLING WATFR SYSTEM LIMITING CONDITION FOR OPERATION 3 7 4 At least three Independent essential coding water loops shall be OPERABLE ALICBLITY MODES 1,2,3, and 4 ACTIf a W*th only two essential coding water loops OPERABLE, wt"ln7 days restore at least three loops to OPERABLE status 6r apply the requirements Of Spedflcatlon 3.13. OR be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b With two or more essential tooling Wate loops Inoperable. within 12 hot" restore at leasttwo loops to OPERABLE status or apply the requIrementst Of
$peclfication 313, OR be in at least HOT STANDBYwIthn the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and In COLD SHUTDOWN within the following 30 hows 4
Implementation
" Option to use the existing TS allowed outage time for routine plant activities ("front-stop" time)
- Also provides sufficient time to apply the CRMP
" Once a component has exceeded its front stop time, the CRMP must be applied to determine the allowed outage time for configuration changes until no components are in actions beyond their frontstop time.
- Could be more restrictive than existing frontstop times 9
Specifications Affected Selected instrumentation of TS 3.3 Atmospheric Steam Relief Code safety valves Component Cooling Water Pressurizer PORVs Essential Cooling Water Accumulators CRE HVAC ECCS FHB HVAC RHR Essential Chilled Water RWST SDGs and Off-site circuits RCB Purge Batteries Containment Spray ESF Buses Containment Fan Coolers AFW MSIVs 10 5
Comparison to "Standard RITS"
" TS 3.13 format is different, but the application is the same
" Applies in MODE 1-4 for SSCs modeled in the PRA
"*Would apply to conditions where TS 3.0.3 currently applies.
"* References the Implementation Guidelines
- Takes exception to proscription against allowing loss of function 11 DG-1122 Pilot
" Submittal is proposed as a DG-1 122 pilot application
" Pilot application requires substantial effort
- Complete response to Peer Review
- Detailed information will not be ready at the time of the first submittal
" STP PRA has undergone extensive review in the past
- 7 Licensing applications since 1994 12 6
RISK INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)
RISK MANAGEMENT TECHNICAL SPECIFICATION INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS I- RESPONSIBILITY I I Technical "* TSTF-422 submitted to
- The NRC has expressed concerns CEOG - TSTF-422 RO Specification Required NRC on January 24, that.TSTF-422 allows staying in Actions Preferred End 2003. the preferred end state when there BWROG - TSTF-423 RO States is a lo.ssof safety function as (Being Developed)
"* TSTF-423 to be "defined by the LCO. The NRC submitted to NRC on will complete their review and BWOG - TSTF-431 RO 6/03. isste, an SE after this issue is (Not created)
.resolved.
WOG - TSTF-432 RO 0 TSTF developed a list of needed (Not created) changes to TSTF-422 based on NRC comments. List created and discussed at the 12/18/02 RITSTF meeting.
- - TSTF-422, Rev. 1 was submitted to the NRC on 1/24/03.
" The BWROG SE was issued 9/27/02.
"* BWROG Topical A version was issued in 2/03.
"* TSTF-423 is being developed based on the approved Topical and is scheduled to be submitted to the NRC 6/03.
NEI RITSTF '
NEI Biff Bradley, 202 739-8083 WOG Jack Stringfellow, Southern Nuclear, 205 992-7037 CEOG Alan Hackerott, OPPD, 402 533-7276 Tony Pictrangelo, 202 739-8081 Jim Andrachek, Westinghouse, 412 374-5018 Gary Chung, SCE, 949 368-9431 EXCEL Don Hoffman, 301 984-4400 Jerry Andre, Westinghouse, 412 374-4723 Ray Schneider, CE, 860 731-6461 EPRI Frank Rahn, 650 855-2037 BWOG Noel Clarkson, Duke, 864 885-3077 " BWROG Rick Hill, GE, 408 925-5388 John Gaertner, 704 547-6169 R. Schomaker, Framatome, 434 832-2917 Dusty Rhoads, Energy Northwest, 509 377-4298 Mike Kitlan, Duke, 704 373-8348 Don McCamy, TVA 256 729-4595 Page 1 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 2 Missed Surveillances
- TSTF-358, R6, has
3 Increase Flexibility in
- TSTF-359 R8 TSTF provided TSTF-359 R7 to TSTF-359 R8 Mode Restraints LCO submitted to NRC on NRC with changes to match the 3.0.4 12/4/02. final completed Safety Evaluation on 7/10/02.
- NRC received 4 sets of comments. NRC currently resolving the comments and plan to finalize the CLIIP Notice of Availability in 10/2002.
- TSTF-359, Rev. 8 submitted on 12/4/02. Notice of Availability expected late March 2003.
4a Individual Risk Individual Owners Ongoing Various Informed Allowed Groups (OGs) and Outage Times (AOTs) plants are pursuing individual Risk Informed AOTs through Topicals and license amendments.
Page 2 of 0 03/05/2003 3
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER I STATUS RESPONSIBILITY 4b Risk Informed AOTs I* TSTF-424 and the NRC provided comments on the TSTF-424 RO With Configuration Draft Risk NEI White Paper.
Risk Management Management Guide Program or were provided to the RITSTF provided an Integration Maintenance Rule NRC on 1/21/03. Plan with schedules 8/15/02.
Backstop RITSTF provided a draft Risk Management Guidance Document 10/31/02.
S RITSTF has coordinated with CEOG and the other pilot programs to ensure a single coordinated methodology and process for Initiative 4b. This single process and overall pilot for Initiative 4b will be supported by the multiple individual plant and Owners Group pilot plants.
RITSTF has coordinated with South Texas Project (STP) to integrate the generic Initiative 4b and the STP approach.
TSTF-424 and the Draft Risk Management Guide were provided to the NRC on 1/21/03.
The STP application will be provided as a letter of intent by 3/03.
NRC is putting together a Task Action Plan to determine action and schedule for review.
i 1 _________________________ .1. __________________________________ L 03/05/2003 of 10 Page 33 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 4b Risk Informed AOTs TSTF-424 and the Draft With Configuration Risk Management Guide
- NRC plan is to get initial Risk Management were provided to the NRC responses to Industry in 5/03 Program or on 1/21/03.
Maintenance Rule Backstop 5a Relocate Surveillance
- Deterministic portion TSTF reviewing candidate SRs to None assigned Requirements Not of Initiative 5 be relocated.
Related to Safety transferred to TSTF rsnilt TSTFby will9/30/03.
provide a TSTF to the
/responsibility.
,. [NRC S:
V Ii A I.;
i ..
I.l Page 4 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 5b Relocate Surveillance a RITSTF/BWROG/Pilot 0 NRC provided comments on the "1TST-425 KU Test Intervals to Plant will be applying RITSTF White Paper. BWROG (Not created)
Licensee Control the methodology and developed a Guidance Document interfacing with the from the White Paper and NRC NRC on the issues in and Industry comments and 2003. provided to RITSTF.
" BWROG provided a revised Guidance Document to the R1TSTF for review 3/4/03.
"* RITSTF to provide comments to the BWROG by 3/25/03.
"* Draft Traveler of just the marked up Technical Specifications to be developed by 4/15/03 for RITSTF/TSTF review.
" RITSTF to provide the Draft Guidance Document and the draft TSTF of the marked up Technical Specifications to NRC by 5/03
" BWROG has identified a pilot plant and will develop a draft Traveler based on the application of the methodology. BWROG will attach the Guidance Document to the TSTF.
" TSTF-425 to be submitted to NRC 12/15/03.
__________ I _______________ I _________________ &
Page 5 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 6a Modify LCO 3.0.3 0 On hold.
- On hold for resolution of None assigned Actions and Timing 1 Initiative 6b and 6c to determine hour - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if Initiative 6a is required.
6b Provide Conditions in
- NRC drafting Safety 0 CEOG to provide revised version TSTF-426 RO the LCOs for Those Evaluation. to address the RAIs to NRC in (Not created)
Levels of Degradation 5/03.
Where No Condition Currently Exists to 0 NRC will finalize the SE based Preclude Entry Into on the CE responses and should LCO 3.0.3 have it completed by 7/03.
- CEOG to provide a list of ISTS changes and justification to TSTF after NRC completes Safety Evaluation in 7/03.
0 TSTF to prepare and submit TSTF-426 to NRC after receipt of NRC SE and receipt of information from CEOG. Current schedule for TSTF to NRC is 9/03.
Page 6 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 6c Provide Specific Times
- NRC drafting Safety
- CEOG to provide revised version TSTF-426 RO in the LCO For Those Evaluation. to address the RAIs to NRC in (Not created)
Conditions That 5/03.
Require Entry Into LCO 3.0.3 0 NRC will finalize the SE based Immediately on the CE responses and should have it completed by 7/03.
0 CEOG to provide a list of ISTS changes and justification to TSTF after NRC completes Safety Evaluation in 7/03.
e TSTF to prepare and submit TSTF-426 to NRC after receipt of NRC SE and receipt of information from CEOG. Current schedule for TSTF to NRC is 9/03..
.. t. , I Page 7 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS I RESPONSIBILITY I 7a Impact of Non "* TSTF-427 transmitted "* RITSTF provided draft Rev. 3 of TSTF-372 R2 Technical to NRC on 3/4/03. TSTF-372 that addresses the Specification Design NRC comments of 12/13/02 letter TSTF-427 RO Features on " Draft Revision 4 of on 1/13/03.
Operability TSTF-372 in Industry Requirements review. Submit "* On January 30, NRC stated that Barriers revision to NRC in they had additional comments on 4/03. TSTF-372.
" On a conference call on February 13, the NRC stated they still had concerns regarding snubbers affecting more than one train of a system and requested changes.
TSTF to develop revision incorporating NRC requested changes for Industry discussion.
"* Draft Revision 4 of TSTF-372 created. NRC reviewed and agreed it addressed their comments. Draft being reviewed by TSTF, RITSTF, and Snubbers Users Group. Plan is to submit revision to NRC in 4/03.
" Draft Traveler for Initiative 7a (TSTF-427) drafted for discussion with the RITSTF on 12/18/02 and NRC 12/19/02.
"* TSTF-427 transmitted to NRC on 3/4/03.
J ______________________ .1__________________________ £ Page 8 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS . RESPONSIBILITY 7b Impact of Non TS
- R1TSTF will develop a White None assigned Design Features on Paper to outline the process to Operability address this scope of SSCs by Requirements - All 5/1/03..
other SSCs not in Technical R1TSTF/TSTF will work with the Specifications NRC on a risk informed revision of GL 91-18 and integrate the Initiatives.
- R1TSTF/TSTF will develop a TSTF and submit to NRC by 6/30/03.
8a Remove or Relocate A White Paper on the
- NEI 00-04 is being reviewed and None assigned Systems LCOs That application of the 10 will serve as the basis for Do Not Meet the 4 CFR 50.36 criteria is Criterion 4 application.
Criterion of 10 CFR being developed.
50.36 From Technical R1TSTF will develop a White Specifications Paper to outline the guidance and methodology based on NEI 00-04 for the application of the four criteria of 10 CFR 50.36 and a list of the systems identified for relocation. -RITSTF working on the schedule - current plans are third quarter 2003.
Page 9 of 10 03/05/2003
RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 8b Modify 50.36 Rule to
- Requires Rulemaking
- R1TSTF looking at coordinating Not applicable Permit Removal or Initiative 8b with longer term Relocation of Non initiatives given the requirements E; I"'
Risk Significan1 for rul'ehiaki"g. e equ n Systems out of, I-, Technical Specifications BWOG - Active in Initiatives 1, 4 and 7
,CEOG - Active in Initiaties l,'4, 5 and 6:
BWROG Active in Initia'iiveg lI 4,5"and 8
- r. ,, . .. . .. .4 !nd iWOG - ActiveiInitiatives 1,.4,,and 5 .
rl I:
Page 10aof 10 03/05/2003