ML031500700

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Summary of Meeting with Risk-Informed Technical Specification Task Force (RITSTF)
ML031500700
Person / Time
Issue date: 05/29/2003
From: Kerri Kavanagh
NRC/NRR/DRIP/RORP
To: Bradley B
Nuclear Energy Institute
Tjader T., NRC/RORP, 415-1187
References
Download: ML031500700 (25)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

.2 *A May 29, 2003 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 1 Street, NW Washington, DC 20006-3708

SUBJECT:

MAY 15,2003:

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 May 15, 2003.

Sincerely, Kerri Kavanagh, Acting 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
4. RITSTF Initiative Status
5. Initial Staff Impressions of RMTS Risk Management Guide
6. Presentation Vugraphs on BWROG Initiative 5b Method" cc w/encl: See attached page

DOCUMENT NAME: G:\RORP\TSS\TJADER\RITSTF-MTGsum-5-15-03.wpd OFFICE TSS:RORP:DRIP . ASC:TSS:RORP:DRIP I NAME TRTjader 7-F KAKavanagh JX DATE 05.Z~/2003 05/2 ,/2003 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 Mr. Gene Kelly Mr. David Helher Exelon Exelon

DISTRIBUTION:

ADAMS PUBLIC TSS R/F TSS Staff DMatthews/FGillespie (RidsNrrDrip)

WDBeckner (RidsNrrDripRorp)

SCBlack (RidsNrrDssa)

MDTschiltz (RidsNrrSpsb)

JZwolinski (RidsNrrDlpm)

JNHannon (RidsNrrDssaSplb)

TRQuay (RidsNrrDipmlehb)

OGC (RidsOgcRp)

ACRS/ACNW (RidsAcrsAcnwMailCenter)

MLWohl (MLW1)

NSaltos (NTS)

WScott (WES)

GSShukla (GSS)

SPWall (SPW)

WDReckley (WDR)

FMReinhart (FMR)

CKDoutt (CKD)

AWMarkley (AWM)

SLMagruder (SLMI1)

RFDudley (RFD)

DFThatcher (DFT)

MACaruso (MAC)

MLScott (MLS3)

EMMcKenna (EMM)

MACunningham (MAC3)

ASKuritzky (ASK1)

MTMarkley (MTM)

WEScott (WES)

SDAlexander (SDA)

MDrouin (MXD)

MCThadani (MCT)

TAReed (TAR)

SWest (KSW)

SUMMARY

OF THE MAY 15,2003, 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 May 15, 2003, from 8:30 a.m. to 10:00 a.m. The meeting attendees are listed in Enclosure 2.

The agenda (Enclosure 3) consisted of discussions of the six active RITSTF initiatives. The RITSTF provided a summary of the status of the initiatives (Enclosure 4). Following is a brief description of the status of the initiatives in the order in which they were discussed.

Initiative 3, TSTF-359, Modification of mode restraint requirements of LCO 3.0.4 & SR 3.0.4:

The staff published the final CLIIP Federal Register Notice announcing availability of this change on April 4, 2003. NEI will be conducting a workshop in Boston, on July 17, 2003, for operators and PRA practioners on implementation of initiatives 2 and 3; the staff has been invited to attend.

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-plant STP pilot proposal in support of the DG-1 122 Office of Research effort on PRA quality and this initiative. The NRC staff has commenced the review process for the RMTS Risk Management Guide and TSTF-424 submittals. The staff provided (Enclosure 5) initial impressions of the RMTS Risk Management Guide. The RITSTF would like to meet with the staff to discuss potential RAls as soon as they are available.

Initiative 7, Non-TS suDport system impact on TS ooerabilitv determinations: The RITSTF plans to delay submital of TSTF-372, Revision 4, on snubber inoperability due to issues with the staff approach to multi-train inoperabilities. TSTF-427, addressing hazard barrier inoperability, is currently under review by the staff.

Initiative 1, TS Actions End States Modifications: The BWR topical SER was issued on September 27, 2002. The BWR TSTF-423 is being developed. 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 very near future.

Initiative 6, Modification of LCO 3.0.3 Actions and Completion Times: 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 6, Relocation of non-safety SRs (5a) and relocation of all SR frequency requirements (5b) out of TS: The RITSTF is developing a Guidance Document on an Initiative 5b methodology. The RITSTF presented a briefing on the UBWROG Initiative 5b Method,"

(Enclosure 6). The staff has determined that this proposal may conflict with the requirements of 10 CFR 50.36. Limerick and Peach Bottom have volunteered to be pilot plants to test the proposed program and procedures.

Enclosure 1

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. NEI noted that the priority of Initiative 8b, on rule making, may need to be increased if an appropriate methodology cannot be found for Initiative 5b, or if other problems arise.

The next NRC TSS/NEI RITSTF meeting will be scheduled for either July 16 or July 18, 2003, in Boston. The NRC is hosting an Operability Workshop, to update Generic Letter 91-18, on August 14, 2003, at the NRC Headquarters in Rockville, MD.

NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE ATTENDANCE LIST MAY 15, 2003 NAME AFFILIATION TONY PIETRANGELO NUCLEAR ENERGY INSTITUTE BIFF BRADLEY NUCLEAR ENERGY INSTITUTE BRIAN MANN TSTF/EXCEL SERVICES FRANK RAHN EPRI JIM ANDRACHEK WESTINGHOUSEJWOG MIKE KITLAN DUKE ENERGY JACK STRINGFELLOW SOUTHERN NUCLEAR OPERATING COMPANY J. E. DUSTY RHOADS ENERGY NORTHWEST/BWROG DREW RICHARDS STP NOC SCOTT HEAD STP NOC BOB SCHOMAKER FRAMATOME-ANP RAY SCHNEIDER WESTINGHOUSE PSA DON McCAMY BWROGIrVA GENE KELLY EXELON DAVID HELHER EXELON BILL BECKNER NRC/NRR/DRIPIRORP BOB DENNIG NRC/NRR/DRI P/RORP/TSS KERRI KAVANAGH NRC/N RR/DRI P/RORP/TSS PETER HEARN NRCINRR/DRI P/RORP/TSS CARL SCHULTEN NRC/NRR/DRIP/RORPITSS NICK SALTOS NRC/NRR/DSSAISPSB MILLARD WOHL NRC/NRR/DSSA/SPSB MARK CARUSO NRC/NRR/DSSA/SPSB CLIFF DOUTT NRC/NRR/DSSAISPSB GEORGE THOMAS NRC/NRR/DSSA/SRXB WAYNE SCOTT NRC/NRR/DIPMIIEHB SCOTT WALL NRC/NRR/DLPM/LPD1 Enclosure 2

AGENDA TSB/NEI RITSTF Meeting May 15, 2003 from 8:30 AM to 12:30 PM, in 0-13 B4 o Status of Initiatives o Initiative 3, LCO 3.0.4 & SR 3.0.4 (Mode Restraint) Flexibility Success July 17, 2003 Workshop on Implementation of Initiatives 2 & 3 o Initiative 4b, RI AOTs with CRMP Review of:

Industry proposed approaches, pilots RMTS Risk Management Guide CE Pilot, TSTF-424 o Public Questions and Discussion o Initiative 7, Non-TS Support System Inoperability Impact on TS System & TSTF-372 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 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

RISK INFORMEI) TECIINICAI, SPECIFICATION TASK FORCE (RITSTF)

RISK MANAGEMENT TECIINICAL SPECIFICATION INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY T eclinical . TSTF-422 submitted to . The NRC has expressed concerns CEOG - TSTF-422 RO Specification Rcquired 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 loss of safety function as (Being Developed) a TSTF-423 to be defined by the LCO. The NRC submitted to NRC in will complete their review and BWOG - TSTF-431 RO 6/03. issue an SE after this issue is (Not created) resolved.

WOG - TSTF-432 RO

  • 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. I was submitted to the NRC on 1/24/03.
  • 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 Nl'l 1illlBradley. 202 739-8083 WOG Jack Stringrellow, Southern Nuclear, 205 992-7037 CEOG Alan lack;rolt, OP'l), 402 533-7276 l'ony ietrangelo. 202 739-8081 Jim Adractiek, Westinghoise, 412 374-5018 Gary Chung, SCE, 949 368-9431 l,XCIL I)on I lollinan, 301 984-4400 Jerry Andrc, Westinghouse, 412 374-4723 Ray Schneider, CE, 860 731-6461 I.l'RI Frank Rahn, 650 855-2037 BWOG Noel Clarkson, Dukc, 864 885-3077 13WROG Rick l ill, GE, 408 925-5388 Jolin Gaertner, 704 547-6169 R. Schonaker, Framatome, 434 832-2917 Dusty Rhoads, Energy Nortlhwcst, 509 377-4298 Mike Kitlan, I)uke, 704 373-8348 Don McCamy, TVA 256 729-4595 Pn,. I nfln

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 2 Missed Surveillances

3 Increase Flexibility in

  • TSTF-359, R8, has . TSTF provided TSTF-359 R7 to TSTF-359 R9 Mode Restraints LCO been approved and NRC witl changes to match the 3.0.4 published for CLIIP final completed Safety Evaluation adoption. on 7/10/02.

. TSTF-359, R9, has . CLIIP FRN on 8/2/02.

been approved by NRC

  • NRC received 4 sets of and will be posted on comments. NRC currently NRC web site, resolving the comments and plan to finalize the CLIIP Notice of Availability in 10/2002.

TSTF-359, Rev. 8 published for availability on 3/26/03.

TSTF submitted TSTF-359, Rev. 9, to NRC on 4/28/03 incorporating changes made in the Notice of Availability, NRC has stated that Rev. 9 is approved and will be posted on NRC web site.

4a Individual Risk . Individual Owners

  • Ongoing Various Informed Allowed Groups (OGs) and Outage Times (AOTs) plants are pursuing individual Risk Informed AOTs tlrough Topicals and license amendments.

PnpeO i rin n l f mnn,

RITSTF INITIATIVE STATUS INITIATIVE 4b TITLE Risk Inormed AOTs

  • INITIATIVE

_ _ _STATUS TSTF-424 and the

  • NEXT ACTIONS/ SCHEDULE/

RESPONSIBIITY NRC provided comients on the I TSTF NUMBER TSTF-424 RO With Configtiration 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.
  • 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

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t RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 4b Risk Informed AOTs TSTF-424 and the Draft

  • NRC plans to get initial responses TSTF-424 RO (continued) Witli Configuration Risk Management Guide to Industry in 5/03 Risk Management were provided to the NRC 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 responsibility.

  • TSTF will provide a TSTF to the NRC by 9/30/03.

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RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER

_ _ .*Z~~~--

.* STATUS RESPONSIBILITY e I r l . n 5b Relocate Surveillance I* RITSTF/BWROG/Pilot NRC providecd comibents on the TSTF-425 RO Test Intervals to P'lant will be applying RITSTF White Paper. BWROG (Not created)

Licensee Control the metlhodology and developed a Guidance Document interfacing with the from the White Paper and NRC NRC on the issues in and Indtustry comments and 2003. provided to RITSTF.

  • BWROG provided a revised Guidance Document to the RITSTF for review 3/4/03.
  • Draft Traveler ofjust the marked up Technibal Specifications to be developed by 7/15/03 for RITSTF/TSTF review.
  • RITSTF to provide the Draft Guidance Document and the draft TSTF to NRC by 7/03
  • BWROG has identified two pilot plants 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 in 1/04.

_ __ _ _ I_ _ _ __ _ _ _ _ _ _ _ _ _ _ L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __I_ I Pirt nrlin n: l I lrnl

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSII31LITY 6a Modify LCO 3.0.3

  • On hold. . On hold for resoluti6n of None assigned Actions and Timing I 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
  • CEOG to provide revised version TSTF-426 RO the LCOs for Those Evaluation. to address the RATs to NRC in (Not created)

Levels of Degradation 7/03 Where No Condition Currently Exists to

  • NRC will finalize the SE based Preclude Entry Into on the CE responses and should LCO 3.0.3 have it completed by 9/03.
  • CEOG to provide a list of ISTS changes and justification to TSTF after NRC completes Safety Evaluation.
  • 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 11/03.

.I.......,1 .

RITSTF INITIATIVE STATUS INI'IATIVE 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 RAls to NRC in (Not created)

Conditions That 5/03 Require Entry Into LCO 3.0.3

  • NRC will finalize the SE based Immediately on the CE responses and should 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.
  • 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.

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RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 7a Impact of Non

  • Draft Revision 4 of :TSTF-372 TSTF-372 R2 Technlical to NRC on 3/4/03. created on 2/24/03. NRC Specification Design reviewed and agreed it addressed TSTF-427 RO Features on
  • Draft Revision 4 of tleir comments. Draft being Operability TSTF-372 determined reviewed by TSTF, RITSTF, and Requirements - to not meet the original Snubbers Users Group (SNUG).

Barriers goals of the change.

TSTF and SNUG to

- address issue with and SNUG is that TSTF-372 as NRC management. structured is not beneficial and does not meet the original goals of the change. TSTF to work with the SNUG to address the issue with NRC management in order to accomplish the goals of the Traveler as originally proposed by NRC.

  • Draft Traveler for Initiative 7a (TSTF-427) drafted for discussion with the RITSTF on 12/18/02 and NRC 12/19/02.

Pr,e or n

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS IRESPONSIBILITY 7b Impact of Non TS

  • A White Paper on the
  • RITSTF will develop a White None assigned Design Features on process to address this Paper to outline the process to Operability scope of SSCs is being address this scope of SSCs by Requirements - All developed. 12/03.

other SSCs not in Technical

  • RITSTF/TSTF will work with the Specifications NRC on a risk informed revision of GL 91-18 and integrate the Initiatives.
  • RITSTF/TSTF will develop a TSTF and submit to NRC by 2/04.

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

  • RITSTF 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.

Pre nf in

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE NEXT ACTIONS/ SCHEDULE/ TSTF NUMBER STATUS RESPONSIBILITY 8b Modify 50.36 Rule to . Requires Rulemaking . RITSTF looking at coordinating Not applicable Permit Removal or Initiative 8b with longer term Relocation of Non initiatives given the requirements Risk Significant for rulemaking.

Systems out of Technical Specifications BWOG - Active in Initiatives 1, 4 and 7 CEOG - Active in Initiatives 1, 4, 5 and 6 BWROG - Active in Initiatives 1, 4, 5 and 8 WOG - Active in Initiatives 1, 4, and 5 n

INITIAL STAFF IMPRESSIONS OF RMTS RISK MANAGEMENT GUIDE l.a. Times for performing risk assessments need a rational basis. Why 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for emergent conditions; why not 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or less; why not minutes? How is [6] hour "re-assessment" time limit implemented? Why 30 days for the backstop time; what precludes a NOED at that point?

[pages 4, 8,10,13]

l.b. Why is reliance on front stop CTs appropriate for multiple inoperabilities. [page 15]

2. Terms need to be better defined and explained; "functional" vs 'operable', "degree of residual capability", "intended" vs "specified", urestored to service", "key safety function", "RMTS tool" vs "quantitative risk assessment tool", etc.

3.a. How does risk assessment of (a)(4) differ from risk assessment of "inoperability"/for determining appropriate CT? Says the assessment process will be "three tiered' but the tiers are not discussed. Guidance needs to be more detailed and explicit. [pages 4, 8]

3.b. PRA Quality considerations need to be defined; depth/rigor "commensurate with complexity of plant configuration"; qualitative vs quantitative vs blended risk assessment requirements need to be explicit. Shouldn't level 3 ASME PRA standards be required for technical specification work rather than level 2? What is more important than operational safety? [pages 13,14]

3.c. Why is consideration of transitional risk optional? [page 7]

4.a. It is not evident what decisions or actions the quantitative and qualitative considerations discussed refer to or how they relate logically (to the unspecified action or decision). What acceptance criteria will the results of these considerations be tested against?

Qualitative Consideration 1 and 3 seem to be redundant since they both address impact on "key safety functions." [pages 15, 16]

4.b. Why are acceptance criteria of RG 1.177/1.174 not used? They seem entirely appropriate for TS work. [page 19]

5. Use of figures needs work. The static nature of figure 3-1 does not capture the dynamic nature of emergent conditions. For example, what happens when an emergent condition creates a configuration that is outside the modeling capability of the PRA so that calculation of a RICT is not possible? The discussion of determining a RICT under Process Description is hard to follow and could benefit from use of a diagram. [pages 4, 5, 11, 26]
6. The discussion of RMTS and RMTS Assessment Scope is very confusing. What about initiating events caused by out-of-scope components; how are they captured? [page 14]
7. The staff fully supports and expects that RMTS Quantitative Risk Acceptance Guidelines will be implemented that include both instantaneous and cumulative performance indicators, and used to assess risk management as an element of a unit's annual NRC assessment.

[page 21]

Enclosure 5

BWROG Initiative 5b Method Presentation to the NRC RITSTF Meeting m

0 May 1 5, 2003 0

LI) c (D

c.'

Exelon & BWROG

Project Definition

  • Initiative 5b project has 2 pilots

- Limerick (STS plant)

- Peach Bottom (ITS plant)

  • Both have fire PRAs V Both plants have SMA
  • Both plants have addressed peer review comments and have updated their models
  • Both have full level 2 PRAs
  • Shutdown PRA - Peach Bottom only

Tech Spec Initiative 5B Process Process Highlights

  • Pilot project to demonstrate method for optimizing. STIs
  • Use DG 1122 (current version)
  • Sixteen candidate STIs

- Testing all elements of the method

  • Fee waivers will be requested for both pilots and the TSTF

Risk Informed Initiative 5b Peach Bottom and Limerick Can Be Modeled Current ~~~(including.

Shutdown, Fire, mpractical Fire Seismic l R-STI LEG I Candidate Surveillance l Cu§nTS Modeled Modeled Seismic) to Modei (Currently (Currentfly Bneflts RI-TILEG Cndiat Suvellace Frequency Modled Moew (Step 27) Modeled) Modeled) Bnft High Low ~High Low

1. LGS EDG Run (and UV relays) M x Can be No On-line work coordination
2. CRD Notching 2. CRD Notching Ww x ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

on-line work coordination; No No reactivity management.

3. LOCA LOOP 3. LOCA I LOOP R R X

~~~~~~~~~_ Can be NonMan-hours; Can be ~~~~~~~~~x No M length outage work control; outage Outage work control; outage length

4. HPCI /RCiC 15 # Test R x No No
5. PBAPS Valve Lineup Venfication M = Yes .. Man-hours: ALARA
6. LGS Turbine Valve Testing (SV, CV. OaX . Man-hours; on-line work coordination; MSIV) RPS Channel TestxTest Yes No production risk; reactivity management
7. PSAPS UV Bus Relays M x Yes - Man-hours; production risk
8. Bridge Crane (Interlocks) W x No No Outage work control; outage length
9. PBAPS Low Pressure ECCS Instrument a x Yes Man-hours, production risk (LPCI, Core Spray) .
10. LGS NSSSS LSF (DAN High Pressure) R X Can be No Outage work control; outage length; man-NSSSS Logic System Functional _ Can_be_No_ours
11. CRD Individual Accumulator Pressure W x No No Man-hours; ALARA; reactivity management
12. SGTS / RERS Flow M x No No Man-hours
13. LGS IRM / SRM Nls W X No No Outage work X

control; outage length;

~~~~~~~reactivity management

14. LPRM Calibration (TIP System) 000 MWD/T Man-hours; production risk; reactivity
15. DC Battery Charger R x Yes No Outage work control; outage length
16. SDV High Level Float Switch 0 x Can be No Man-hours Legend:

M = Monthly W = Weekly O = Quarterly R = Refuel Cycle 05/1303

Schedule

  • Method to NRC for review July 2003
  • Anticipate submittal of both LAR and TSTF in January 2004 Combined submittal
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