ML040020047

Enclosure 5: Rmts Rmg NRC Review Comment Resolution Responses

ML040020047
Person / Time
Issue date:	12/23/2003
From:	Tjader T NRC/NRR/DIPM/IROB
To:	Bradley B Nuclear Energy Institute
Tjader T., NRC/IROB, 415-1187
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ML033650093	List: ML033650110 ML040020046 ML040020047
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it I i RMTS RMG NRC Review Comment Resolution Responses 12n 11 Comment Comment Supplementary Comnent Supplementary Comment Supplementary Comment Source Ciomment Text Text I Text 2 Text 3 Proposed Comment ResolutionlFResponse Number The document contains misapeled words. The treatment of acraonyms s Inconslstent; some acronyms are never defined others ae defined sftar being used several times,and others re frequentlydefined. Punctuation needsimprovemnr The use of and e g Is not alahys correct and could cau confusion. We concur. We have reviewed the document 1

and corrected theseissues to the best of our ePedally In a guidance document meant to be folowed by ability.

1 NRC Implementers throughout the nucearpower Industry, The Implementation of th proposed RMTS approach needs to The RMTS program guidance Is designed to be consistent with NEI 93-01 (Revision 3) bejustifiedhI accordance with guidance provided In RG 1.177 nd RG1.174. Wll theimpmentation fthe proposed RMTS maintenance rule guidance and with RG 1.174.

Text has been added to the report to describe approachneet the guidance statedIn thes two regulatory guides? If the answeris yes, please discuss how such guidance the RMTS guidance relationship to NEI-93-01, 2 NRC willbe met. RG 1.174, RG 1.177, and RG 182.

The topical report documentingthe risk management guide was prepared by EPRI and CEOG for NEI. It nees to be clearly stated thatthe report Is proposed for both CE and non-CE We concur, and we have added text to resolve (page 11 his comment.

t___________ aagnrl ehuU 3 NRC reactors.

This guide promulgate ageneral technical framework for RMTS programs and is not intended to be a prescriptive procedure or regulatory document We anticipate that the Prasentiy the TS requirements are relatively easy to Inspect Unim the requirements for RUTS arecearty stated in the TS, ikcensees Intending to implement RMTS programs will address prescriptive actions In the Inspectors may have a difficult time verifying the implementation of flxdible completion times. The TS should their respective RMTS program request submittals to the NRC. Also, there are RMTS state that Te bensee's risk assessment and risk management piot programs under current development actions must be sI accordance with (Risk Management Guids,

. How does the RITSTF see the proposed rs management The results of these pilot programs wi4 be used approach filling into the regulatory framework and regulatory to aid in addressing the issues raised by this 4 NRC pmrcess? comment To the extent that these Issues are modeled In a plant-pecific PRA the"s wlN be addressed via the process hI the guide. However, tenoris risk is. and wil remain, outside the scope of the typical PRA unless and until specific Initiating event definitions and frequencies can be suppited by t*h regulator or other competent authority, Intentional acts of sabotage and Recommend that the guide be revised to address maintenance terrorism are outside the scope of the of equipment during: high demand months, bad weather, when CRMPIPRA and are therefore outside the electric demand I high, and other times of external vulnerability, 6 NRC such as plant vulnerabilities to terrorist attacla scope of an RMTS program.

pages 4. 5. 1I, 261 Use of figure needs work. The static nature of figure 3-1 doe not capture the dynamic nature of emergent conditions. For example, what happens when an Text has been added to the report to make It emergent condition creates a configuration that Is outside the dear that, If a RICT assessment Is not possible modeling capability of the PRA so that calculation of a RICT is not possible? The discusion of determining a RICT under for a particular maintenance configuration, then the front-stop CT will apply. Also, Figure 3-1 Process Description Is hard tohlow and could benefit from use 5 NRC of a dlsaram. has been refined.

ENCLOSURE 5

RMTS RMG NRC Review Comment Resolution Responses Commant Comment Supplemenbtry Comment Supplementahy Comment Supplementary Comment Number Souwe Comment Te" Text I Text 2 Text 3 Propomd Comment Resolutlon/Reponse Pae I1I flow cat 1.first stop RICT not requl- should it aWerd not permitted? H who determies whet makes a Fgux 3-1 has been relineo Monioring d qusfied btS to peform a RICM M. imoltor configuration hctors risk is cntinuous during 7 NRC risk -what eeqhe ncv othis? 1__ __ On_ RICT _meoperbdo On page 17 and 18, NIsstated: 7tls akortntf to note Vt a RUM pam ~hot"nfpemftWns Wulm n dWoftan of#Nftrys f kyasftf m O ThIs senTence needs clarification. The sentence should stt ItI Iporant to note tht RMTS progrm SMALL not pemit ,ai A previously ate, tHOs guide provides a simultaneous disabln of al trains of ad trains of any key sae general technical framework for RMTS system and defi a ke aft system Loss of function for program development and Implementation, not

_ NRC ay systems should be addressed outside this Initiative. _ _ re t or regulal renuirements.

Term need to be better defined and explained: functionar vs.

opeW . degre* of residual capeby. Intended' vs.

spelfledf restored t servl e,ky saety fc . RMTS 9 NRC toor vs. quntiatve risk assessment bo. ec. The uide tt andlossary has been refined.

A clr definition should be provided hIAppendix A for the terms We concur Thes definitions hae been 10 NRC = ront-stoo' and added to Apendlx A Po"g 16- Itemn 2; of sBection 3.A.2 states I...to shutdown end mahitain t reactor In a safe shutdown wndilon Define th afe shutdown conditlon' and show Ih reltioship with LCO 3.0.3 of the STS. rele to the shutdown end states. Discuss th Interrelationship of this iniatv with Inftiatve 0 on modifing We concur. This definition has been added to 11 NRC TS 3.0.3. Appentidi A An previousl stated, this guide providles a Review the entire document to ensure Mt when a given general technical framework for RMTS direction Is hmpertv ft utiles an appropiat word, such as, program develpment and Implementation, not 12 NRC sPhuN.' ________ rescriptive or rsauiatoiy requIrements.

p________

1Inome pces It says fire. seismic, and or flood(p.6); fire, floods, and exbern flooding' (p.22). Other pilces It sys

'extenal ven should be considered which I wd inde hurricanes, locel events (e.g.. fire at near-by plant).

bomados Others places just says 'initiating events' without cuing out W have r the document to clarify evised dern events (p.12) Pleasere-elk document tobe treatment of extenal events within a RMTS 13 NRC nt or are events limited to lust the listed events? _

We aurvem Approprate WAK has been added 14 NRC Pates 14/15 add bulet to Inchude 'in_ experienceto tho Page 322nd paagraphs the t '..Addltonal di so non Is presented In Section 5.3.' Section 6.3 Is We aonur Approp revi h been these features

_adebthrport 15 NRC r

_Tbmens MTnot irdnd ad to ah Pae 3; a. What I tha Iplication of. 'The RMTS... wil not dw plantfetyllmhorllmng 5 de d in h co change th marnner Inwhich plant desn parameters arn 15 NRC cantro e.'? _____________specficaions Pae 4: a. How Is risk 'Judfied'? b. How Is Guldano ford continuing maintenance beyond the CT 0rcls*, recomen rewonhi sentence to make dwer t t Isthe continuing maintena beyond th CT that Ist d and not the We concur Appropriate revisions havebeen 17 NRC c ndance_ made to the report.

2

RMTS RMG NRC Review Comment Resolution Responses 12115=03 Comment Comment Supplementary Comment Supplementary Comment Supplementary Comment Number Source Comment Text Text I Text 2 Text 3 Proposed Comment ResolutionlResponse Page 6: a. How do you 'enter a front-top Cr; r clarifying sentence to erpichly state that It Is the LCO Condition

• nd Required Actions tV are being entered? b. What does this meanwNote at Intrmmediat, risk levels plant action wil escalate to be commensurate with the projected risk.? c. The rest of Sect~on 2 appears to be leftover paragraphs that had been We have added the following clarifications for edtten but found no acceptable home In the document these comment Issues: a. This is the cock coherence is needed. d. Note that the NRC has never endorsed start time for the conventional TS AOTICT. b.

Reference 3, which Is revisIon 3 of NE's guidance for 'Note that, during the time a RICT is in effect.

Implbmentation of the maintenance nle. NRC has endorsed plant actions ... c. Appropriate revisions have revision 2 of NUMARC 93-01 plus a revised Section 11 dated been Implemented In the report d. We are 18 NRC February 22. 2000. Comment also aplies to pae 33. intentionally referencing NEI 93-01. Revision 3 Page 6: a. How do you 'ass and manage the risk Impact Incurred from plant configuration risk management'? b. It appears that what Isbeing sald Is that 'the (aX4) process involves a greater reliance on PRA methods and insights In establishing and planning maintenance activitles than implementation of the RMTS wil require: when what is meant is Appropriate revisions have been made to the 19 NRC the Inverse: recommend rewording. _ report to cla ri these Issues.

Page 7: a. What is an *RMTS todor? b. What is the meaningof

'The assessment then rsquires. . . performance of a risk Appropriate revisions have been made to the 20 NRC assessment....-? Recommend reword o clarity. c. rewrt to larity these Issues.

Page 8: a. In (2).. How oo you perlorm a risK assessment of the InoperabOt? Clarify. b. In (2).. Same sentence.. That is done to Justify continued power operation beyond the front-stop.' Suggest adding the 'determination of the feasibility of continued power operation etc? c. In (3) the word manage Is misspelle and a comma Is missing after'manage risk. d. In (4)

. The time lin seems reversed: AFTER entering the extended CT, THEN re-perform the risk assessment e. The first three sentences of the paragraph beginning at tha bottom of the page Appropriate revisions have been made to the 21 NRC need clarity. report to clarif these isues.

In many p where the report previously "aces stated an action 'should' be performed, we have changed "should' to 'must." However, we reiterate that this report Is a technical framework document only, and it Is not intended to be prescriptive or regulatory in nature. Specific documentation guidance will Page 9: a. Agree that the risk assessment ' be be addressed via the RMTS pilot projects and documented. b. How will be the risk assessment be documented via subsequent plant-specific RMTS program 22 NRC and what will be In the documentation? request submitls.

Fgure 3-1:a. 3d box text is Incomplete. b. SIGNIFICANT IS3UE- We have addressed these Issues in the report How are *Qualified Sta selecteddterminedletc. This I a as follows: a. None of the box text is significant isue with respect to al uses of risk assessment c. incomplete, it just was blocked from view. We How do you 'perform' an 'RICT'? d. Next oval ..Who is qualified have fixed the fonttformat. b. This should be to 'review and approve RICT assessment? a. Time line. Is it specified In individual RMTS submittals. c.

appropriate to 'implement configuration- before "establish risk RICT assessment d. Plant-specific RMTS management actions'? f. Next oval.. What are the risk factors to submittals. e. Reversed box order. f. 'Changes be monitored? g. The 'Ye words on the decision branches are In configuration or component operability 23 NRC illegible. __ _ status.' g. Re-formatted figure.

3

RMTS RMG NRC Review Comment Resolution Responses 121520e3 Comment Comment Supplementary Commen Supplementary Comment Supplementary Comnent Number Source Comment Text Text I Text 2 Text 3 Proposed Comment Resolutlon/Responee r"age 13: a. in u - uenne ppmmpw as in prompnry r to sevI. Comment also applie o pegs 28. b.

UNACCEPTABLE. in thes cases, the assessment may consider the me necessary forstoratn of the SSCs hfckn, with respectto th time at which performance of the hfnction would be needed.- This Isse caused major problems In mI rulespace. However, te tenia speclications were always conidered a sft net or backsp to the appicton of this bg It now appear t the RMTS program Isren that s ynetto the benefitof the pn opeto and to the poen detimen of se. In 10..'Prosdural The term 'promp has been cawed In the guidance should be provided to specify the aproprate report. A 244-our RICT reIcwlculation time has completion me for essessing the risk.- To be provided when been applied as an example, but this time has 24 NRC and by whom? been dcarid In the report Page 14: a. Want *a 'equipment maitenanc cnigurallons'?

Clafift b. Next sentno ..What does th mean'... SSCs that We have added appropriate defnitons and have or could have front-stop CT requirements Imposed. .. clarifying text to the report These SSCs am 25 NRC (snmphosis ade)________ those addressed In TS LCO%.

PaeP 15: a. Second bullet.. How we the dependc modeled to ensure adequacy the ssssmen b. Fifth bullet.. If the The mond buetw adeleted by EPRI and the 26 NRC proC Is aibble, should Ht not also be used? i but was clrified Inthe report Page I8: a. There a no malnlenanesrule iqurementa to establish and meet SSC pemance criteria.- Such aspects of Implementng the nrle come tnam NEI guidance and mu not required by the rule. b. How can one observe 'actual tempory risk Impact'? c. The statement that 'Risk management can be We now refer to NEI 93-01, Revision 3 effec accomplishd by uing qualatve insigh from the guidance consastently. Clarifying text was 27 NRC PRA Is not ay tn,_ added to the report Pag 19 The statement thot'Qusltivem eods to establish risk man mn actio would genermal be necessary to address SSCs not modeled In the PRA, and for shutdown condiatn' May bettr be moditied o ac dge that many We concur. Chlaing text was added to the 28 NRC licensees have PRAs ta functio for shutdown conditions. report Pae 20 a. The phnse, 'which events cuse the risk level,'

needs to be dcried. b. The pmenthe phse, 'Lo.. I welymaintenanc plambro'idcate 'that*th onYwa mahinenance can be sJtndlonally m deliberataly pr- The report has been reworded to address 29 NRC schedu i through such a 'weekdy maintenance plan.- True? the issues.

Page 21: a The erroneous statement is made thet 'The quantitatie risk aceptance guidelines presented In Table 3-2 Table 3-2 was ubstantially rvised to be am consistent with NRC Maintenance Rule (NX4) guldance.' consistent with NEI 93-01, Revsion 3 30 NRC Oulte different Table 3-2 Table 3-2 NUMARC 93-01 guidance.

Pae 21: a. The enrneous statement is mad emth 'The _

quantitaiv risk acceptance guidelines preed In Table 3-2 Table 3-2 was substantially revsed to be am consistent with NRC Maintenc Rule (aX4) guidance.' consistent with NEI 93-01, RevisIon 3 31 NRC Qulte df n (Risk A a Gaiddis) (Risk mngement actions) guidance.

Page 21: a. The eroneous statement Is made that 'The quanttative rsk acceptan guidelinespresentedin Table 3-2 Table 3-2 was substantialy revised to be are consistent with NRC Maintenance Rude (aX4) guldance.' consistent with NEI 93401, Revision 3 32 NRC Quite difterent Confik risk not vluntri nr Caed conidferbfon beore en ldance.

4

RMTS RMG NRC Review Comment Resolution Responses 12t1612003 Comment Comment Supplementary Comment Supplementary Comment Supplementary Comment Number Source Comment Text Text I Text 2 Text 3 Proposed Comment Resolution/Response Page 21: a. The erroneous statement is made that 'The quantitative risk acceptance guidelines presented In Table 3-2 Table 3-2 was substantially revised to be are consistent with NRC Maintenance Rule (aX4) guidance.' consistent with NEI 93.01. Revision 3 33 NRC Quite different >10-5 C.R. not voluntarily malntained( Config should not nomialy be e guidance.

Page 21: a. The erroneous statement Is made that 'The quantitative risk acceptance guidelines presented In Table 3-2 Table 3-2 was substantially revised to be are consistent with NRC Maintenance Rule (aX4) guidance.' consistent with NEI 93-01. Revision 3 34 NRC Quite different  :'10-6 (words make no sensel Take risk mgmt actions guidance.

Page 21: a. The erroneous statement Is made that 'The quantitative risk acceptance guidelines presented in Table 3-2 Table 3-2 was substantially revised to be are consistent with NRC Maintenance Rule (aX4) guidance.' consistent with NEI 93-01, Revision 3 35 NRC Quite different <10-li (words make no senseW) Normal work controls guidance.

Page 21: a. The erroneous statement Is made that 'The quantitative risk acceptance guidelines presented in Table 3-2 Table 3-2 was substantially revised to be are consistent with NRC Maintenance Rule (aX4) guidance.' How can 'risk' be greater than consistent with NEI 93.01, Revision 3 36 NRC Quite different 'tiUme'??? ouidance.

Page 23: a. What is the meaning of 'RMTS thresholds? b. On this page It Is stated, 'Risk management actions should be considered for plant configurations whose instantaneous and a. See Table 3-2. These statements are not cumuiative risk measures are predicted to approach or exceed contradictory, if risk management actions (up RMTS thresholds.' it sounds unacceptable; clarify. Compare to and including plant shutdown) are applied with Page 24, where it says: 'Controlled plant shutdown should prior to the end of the front-stop CT, then the be considered for plant configurations whose Instantaneous and predicted risk measures wll improve (i.e.,

cumulative risk measures are predicted to exceed RMTS decrease). Controlled plant shutdown is a risk 37 NRC thresholds.' Which sounds contradictory. management action.

Figure 3-2: a. Define when 'operating risk' is 'unacceptably high.' b. Define when 'projected Integrated risk to complete' is

'acceptable.' c. Define criteria in determination of 'SD risk compensate benefit for increased operational risk?' [Explain the Figure 3-2 has been deleted and replaced by a 38 NRC figure.) ____________ revised discussion lin h eoret

a. We con-cur. Thereport tePxt o een has revised to address this issue. b. In many places where the report previously stated an action 'should' be performed, we have changed 'should' to 'must.' However, we reiterate that this report is a technical framework document only, and it Is not Page 27: a. In 3.6.1 ...The last sentence is misleading. No intended to be prescriptive or regulatory in (a)(4) assessment Isrequired at the time of establishing the nature. Specific documentation guidance will compensatory measure, but one IS required before performing be addressed via the RMTS pilot projects and the maintenance to address the degraded or nonconforming via subsequent plant-specific RMTS program 39 NRC condition. b. in 3.7.2.. Last line.. 'shar or 'must' vice 'should.' request submittals.

Page 38: The definitions of 'functional' and the phrase 'as 40 NRC modeled In the plant-specific PRA' need to be clarified. Revised the report Page 40: The definition of operable Isalmost the same as the We have taken this definition directly from NRC/TS definition: the word 'and' has been replaced with 'or' in standard TS references (e.g., the 41 NRC two places; why? Westinghouse STS).

RMTS RMG NRC Review Comment Resolution Responses 1211512003 Comment Comment Supplementary Comment Supplementary Comment Supplementary Comment Number Source Comment Text Text I Text 2 Text 3 Proposed Comment ResolutlonlResponse age 43: a As a mather orrcora, me pr-US9 verslons of e_

maintenance rule DID NOY require lIcenses to assess and manage risk. as the nkle dose today. b. The etatement th This nrle requires thst a "risk assessmenr be performed prior to volunt entry into a maintenance configuretion.. . Is emoneous. The nils requires a risk asaessment befre a. Comment noted. b. The report has been performing maintenance activities. regardless of configuration or revised to accommodate these revisions. c.

whether equipment will be taken out of service. c. Once again, Reference 3 (NUMARC 93-0.1 Revision 3) is a the guidance for satisfying th requirements of this nde foundational reference for this guide. Revision provision Is defned In Section 1t of NUMARC 93-01 (Refere 3 merely Incorporates the revised Section 11

3) and has been endorsed by the NRC . Note: the NRC has endorsed by NRC In Reg Guide 1.182. and 42 NRC not endorsed Reference 3 contains no other chang from Revision 2.

The 24-hour limit is applied as en example In (pages 4, 8, 10.13, Table 3-11Time for performig risk this guide, but the guide now states that asseas need arational bal. Why 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for emergent specifc "reassessment or RICT "re-omdido; why not 6E hosor kas wqhy ns nmkm How is EG] hour ce ton Uime will be rquired to be within re t time lin imipleanented7 Why 30 days forthe the associated relevant front-atop CT for the 43 NRC o te; cha NOED at ha poinf udes maintenance configuraton of Intarest Pae 5 - 3" paph dismses the realculation of the RICT for The 24-hour lmit is applied as an example in changes matance configurtion. An exmple of 24 hous isused as this guide, but the guide now states that accepbletim to complete the RICT recalculatio. Paroide the basis specific "re-assesmenrt or RICT 're-for te acceptable required time to complete tbe RICT recalculon and calbation" time wfi be required to be within add the risk sinificance of the durain of the reaculation time the associated relevant front-stop CT for the 44 NRC duingwhich tie oriinal tg RICT ibexceede& maintenance con8iguration of interest On page 10. Table 3-1 third coium, it Is stated that anes wih verify that the completion time exension Is acceptable -in accordance with the RMTS Program (i.e., within 24 hous of a subsequent configuration change.' This statements needs to be revised to distinguish between voluntary end involuntary (emergent) con!iuratlon changes. For voluntary configuration changes, the acceptability of the etensin (or continued extension) should be verified befoe entering th new configuation. For emergent conliguraion changes, such The 24-hour Olmit is applied as an example In acceptability should be verified expeditiously (eg., within one this guide, but the guide now states that hoW)to ensure t it Is safe to operate the plant at th Current specific "re-assessment" or RICT 're-configuration until a mor detailed risk assessment Is perlfrmed. cakbition time wil be required to be within A longer period (eg.. 24-hours) can be a11owed lo perform and the assoclated relevant front-atop CT for the 45 NRC document a mor detailed risk assessment, maintenance configuration of interest The staff feels that 30dy complefton time I a very long time for The 30 day backstop is intended to restore an equipment to be h The guide should provide the xIperable. compliance with design basi considerations In basis for establishing a maximum of 30-day completion time. a reasonable time for situations where risk The staff bilevs tha moat of the maintenance and repairs on metrcs would alow longer periods of th safety equipment can be accomplished within 14 days ( Inoperbliity. As a point of reference, temporary based on industry experience a complete overhaul of a diesel plant modifications performed to permit generator can be accomplished wIthin 14 days). Consideration maintenance activities are excluded from 10 need be given to restoring compliance with such GDCs as 17, CFR 50.59 review for a period of 90 days, 34, and 35. and to sngle au criri as soon as practical providing they have been assessed under 10 46 NRC _ hen determinina the aprooriate completion time. _ _ CFR 50.65(a)(4).

RMTS RMG NRC Review Comment Resolution Responses 1211512003 Comment Comment Supplementary Comment Supplementary Comment l Supplementary Comment Number Source Comment Text Text I Text 2 Text 3 Proposed Comment ResolutlonlResponse r=o =intent of the 3s day backstop, and the whole RMTS concept is NOT to increase unavailability of safety systems. Increased unavailability of safety systems is precluded by many measures, including 1) The existing provisions of the maintenance rule to balance unavailability and unreliability based on PRA insights, which would not be affected; 2) The requirement n RMTS for condideration of The staff feels that the unavailability of the safety equipment aggregate risk impacts, and meeting Reg would increase with the proposed completion time of 30 days. Guide 1.174 risk metric guidelines for How would this Increase in unavailability satisfy the requirements permanent CLB changes; 3) Existing of maintenance rule regarding minimizing unavailability of safety performance indicators based on safety system 47 NRC systems. unavalability.

Security risk cannot practically be addressed in the context of RMTS. In times of elevated Has any consideration been given to Nuclear Power Plant security conditions, security programs will security, In light of the recommended long completion times? specify controls as necessary. These Shouldnrt the guide provide guidance on what measures the programs are typically controlled under licensees should take in order to protect the plant equipment safeguards requirements and cannot be 48 NRC during this period? incorporated into Tech Specs.

On page 28, Testing, it is stated that SSCs out of service for testing are considered unavailable, unless the test configuration is automatically overridden by a valid starting signal, or the function can be promptly restored... The guide should define promptly. such as within 5 minutes. It Isnot clear what The report text has been revised to define what 49 NRC Promptly means here, we mean by romp and 'promptlvy" Existing maintenance rule (a)(4) requirements would still apply to the front stop period, and these could result in risk management actions (page 15] Existing completion time (front-stop time) provided in up to and Including plant shutdown, as they do the TS may not be conservative for certain plant configuration ( today. Current tech specs also create the maintenance activities on multiple SSCs). Table 3-1 suggests possibility to create higher risk Impacts due to that the licensees have to verify only the time beyond the front- simultaneous LCO entries, and this was the stop completion times. The licensees have to do a risk rational for the development of (a)(4). The assessment for the configuration they are in to validate the existing front stop values are preserved for the completion time. The approach of this process seems to be purpose of operator familiarity. work planning.

based on the assumption that all complation times specified in and maintaining the general existing approach 50 NRC the existrng technical specifications are conservative, II of tech specs.

RMTS RMG NRC Review Comment Resolution Responses Comment Comment Supplementary Comment Supplementary Comment Supplenbtry Comment Source Comment Text Text I Text 2 Text 3 Proposed Comment Resolutlon/Response Number PRA technical capability would be commensurate with NRC guidance of draft Regulatory Guide DG-1122. This would require, as a mininimum, an ASME capability level 2 Internal events at power PRA for CDF and LERF. It Is not expected that ASME Capability level 3 would be required for PRA technical elements in support of this application. ASME capability level 3 pxquirements generally represent methods that (pign13, 141 PRA Quality cmideritions ned to be defined, go beyond edstng practice for PRAs. and are deqaitgair S. qantate wit. compled ofpleent rafieqiue"; intended to support risk based applications.

qualitative va quantitative vs. bloot asenent . s ded _^pk The RMTS uses a risk inforned approach need to be expliciL Sho9dt level 3 ASME PRA standards bh through application of conservative guidelines reqired for tecind specifiotion work rater than kel 27 What is for risk management actions, use of backstops, 51 NRC moeW ifportt than operationl _t and other measures.

Page 4- e peagraph ste that "...The sernment should oe pafoned ..and rupported by s plsnt..(PRA) and odmer risk

_unmlt trol.. Proide exanples to illustrate what we rho lomhr*isk menanaemen toobl that may bhused. and adrs dwir acceptability for use in risk assessment to sopprt the risk msqemAit The report text has been revised to give 52 NRC _ dide disosd in the topical report, exampes and dscus cceptability RICT values cannot be calcuated for such systems and associated SSCs unless and until they are added to the scope of the PRA In some form, so they would, In general, not be within the scope of the RMTS. In other words, How will TS on systems that do not contribute to CDF or LERF such systems would remain under the control of currant TS LCOs.

53 NRC be addressed: wil this process spply (e.g.. SFP)?

Page 14. Lat paragraph states ...The PRA should meet

..industry standards ...(Se References)...." Where applicable, list the documents or lette by which the NRC either endorses accepts the cited references In support of en acceptable plant See answer to number 50 above 54 NRC PRA for use In the risk manageeent _uld__

That wUi vary depending upon the RMTS-implemnting plant and the scope of Its SSCs addressed In Its CRMPtPRA. This must be addressed In individual plant RMTS program Page 22 mentions plants without xternal events PRAs , how request submittals. This guide supports the full broad of a spectnum are we slowing in term of quality or spectrum of potential RMTS scopes for specific plants.

55 NRC completeness of PRA to apply the RMTS? The ASME PRA Standard (ASME RA-S-2002) and the EPRI PSA Applications Guide (EPRI Page 22 states that plants must approiately consider th Issue TR-105396) address this Issue. Also, NRC of uncertainty -who determines appropriateness? What guides Regulatory Guide 1.174 presents some related auldance.

5S NRC are available to ensure industry unifrmiy?

I

RMTS RMG NRC Review Comment Resolution Responses 12(1512003 Comment Comment Supplementary Comment Supplementary Comment Supplementary Comment Number Source Comment Text Text I Text 2 Text 3 Proposed Comment Rasolutlon/Response The RMTS risk assessment process does not differ materiasly from the associated process for IOCFR50.65 (a)(4). except that the focus in the RMTS is on determination of an acceptable RICT, and there Is more emphasis on 'pre-screening' of maintenance configuration risk in an RMTS program. We have eliminated (pages 4 SI How does risk assessment of (aX4) differ from risk reference to the 'three-tiered' approach in the assessment of "inoperabiity"for determining appropriate CT? Says report, but this has always referred to the three the assessnent process will be "thre tiered' but the tier re not proposed RMTS CT levels: front-stop CT:

discussed. Guidance needs to be arn detailed and explicit_ RICT; and back-atop CT (30 days).

57 NRC No. We see no need for this limit as long as we can calculate a valid RICT. Otherwise, we (page 7] Is there a limit to the number of changes allowed In a will always default to the associated front-stop given period of time, such that a qualitative understanding of the CT. We recommend consistency with risk is known? maintenance rule (a)(4) guidance here.

58 NRC

[pages 15. 161 It is not evident what decisions or actions the quantitative and qualitative eoesiderstiens discussed refer to or how The report has been clarified regarding this they relate logically (to the unspecified action or decision). What issue. We now clearly state that qualitative acceptance criteria will the results of these considerations be tested analysis supports the quantitative analysis against? Qualitative Consideration I and 3 seem to be redundant since required for RICT calculation. The acceptance 59 NRC they both address impact on "key safety functions" criteria are clearly stated in Table 3-2.

page 211 The staff fully supports and expects that RMTS We interpret this to mean that we are In Quantitative Risk Acceptance Guidelines will be implemented that agreement with the NRC here. Table 3-2 lists include both instantaneous and cumulative performance indicators and both instantaneous and cumulative risk metrics used to assess risk management a an element of a umits annual NRC for maintenance configuration safety 60 NRC -assessmient. management.

As previously stated, this guide is based primarily on NUMARC 93-01, Revision 3 guidance, and not directly on RG 1.177.

[pages 6519, Figure 3-21 Why are acceptace guidelines of R However, RG 1.177 Is applied in some RMTS 1.177/1.174 not used? They seem entirely appropriate for this TS programs for selected equipment LCO front-application For example, RG 1.177 acceptance guidelines for a stop CT determination and the general completion time change am an ICCDP of less than 5.02-7 and an guidance from RG 1.174 is applied in concert ICLERP of 5.0E4-or less, are apparently not considered, with NUMARC 93-01. Revision 3.

61 NRC As previously stated, this guide Isbased primarily on NUMARC 93-01, Revision 3 Page 20 -Item 2 states that (quantitative risk acceptance guidance. We believe the acceptance criteria guidelhnes ...are presented in Table 3.2....' Discuss the presented in Table 3-2 are consistent with the acceptability of the proposed acceptance risk guidelines InTable Maintenance Rule guidance and represent 3.2 for use in the RMST risk analysis. Ieneral aood practice.

62 NRC 3

RMTS RMG NRC Review Comment Resolution Responses 12181203 Comment Comment Supplementary Comment Supplenentary Comment Supplementary Comment Number Source Comment Text Text I Text 2 Text 3 Proposed Comment ResolutlonfResponse On page I1, it is stated: ants that Inplement RMTS should develop measures to assess the aggregat risk wffh respect to Ns eetmated knpact on the sverue baselne rds Ths could be We have revised the report to clarify that

_ccomp~ahed through a pedorc assessment of pnWus out-OP qualitative analysis supports the quantitative ser condflons Such an assessment may hWV* analysis required for RICT calculation. Also.

qunfatilyestbnag cumrdaUv Wksor may Iwvoe a we have referred to NUMARC 93-01(Revislon qufvet*y assessing the rsk management approach employed 3), RG 1.174. and EPRI TR.105396 for ve the actual tamporery rftk hacs Oserved ' The staff aggregate risk management guidance.

believes that guidance I needed on developing and using Individual plants wil be required to address messures to *ses the aggregate risk with respect to its aggregate risk management In their plant-estimated Impact on the average baseline sd based on RG specific RMTS program request submittals to 1.174 criteria. Also earfiaton i needed on how a qulivtate the NRC. It Is anticipated that many of the assessment of the risk management approach veraus the actual detais regarding aggregate risk management temporary risk Impact can be used to ensure that the plntrs within a RMTS program wil be addressed via basellne rlsk willn ot inaae by the implementatlon of the the plot plant examples currently under 63 NRC Mwoset RMTS progr m_ development On page 7. it Is stated: 'in performing the RMTS assessment, Yes. We generaly agree with the staff here.

the decision makdng process may optionaly include Plants addressing Issues of transition risk in consideration of transition risks associated with mode changes.' their RMTS programs wil be expected to Does this statement Imply a quantitative consideration? The perform adequate conservative bounding staff believes that for a quantitative consideration of 'nsition' calculations to support RICT determination, or rak, Ifoenseea wi1 need appropriate models to ensure that the they will altematively be expected to apply credit taken for avolding transition risks (by contiued operation transition risk models In the RICT 64 NRC at po s not overestimated, determination Process.

On pages S and 7. itms 1 to 4. several attributes that the RMTS process should have (inaddition to MR (aX4) attributes) are listed. These attributes relate to the development of procedures and guidance for Implementing the RMTS process. For example, it states that the RMTS process shall '. Be docmented hr plant procetures defesthg sApOPrIate r oWRes hbr (a)(4) relted .tons 'a*nd kdeguidnce No. The individual plants wili develop these for ufgdsk hksmto menage ovemplant isk Are these procedures and guidance in support of their ttrlbuts explained Inthe RMTS Risk Management Guide? planspecific requested RMTS program Who i uolnu to develo such procedures and Auldsnce? submittals to the NRC.

55 NRC 10

RMTS RMG NRC Review Comment Resolution Responses 121M512003 Comment Comment Supplementary Comment Supplementary Comment Supplementary Comment Number Source Comment Text Text I Text 2 Text 3 Proposed Comment Resolutlon/Response un page D, n ISs5la0 -elonienfr wrniwe maintenance 717ea_

tarvet RMTS configuration risk would be a configuration ICDP of IE-O (as measuted from entbyhto the RMTS). For emergent conrhtions (or fortd,9 unplanned extension of planned maintenance) a mawimum RICTequialent to an ICOP of 1E4 Is Widf -' It is not clear why an ICDP of IE-6, measured from entry Into the RMTS, Is consistent with the maintenance rule, It appears that If the ICDP were measured from the time the component Is taken out for maintenance, the ICOP could be signlifcantly above the I E-6 target for 'normal work controls.'

Also, the exact meaning of the statement tforced, unplanned extension of planned maIntenance' needs to be clarfied. Is the underestimation of the time needed to perform maintenance on The report has been revised to refer to certain systems Included in this statement? It appears that only maintenance rule guidance' (NUMARC 93-01, one such case per year is likely to cause a significant Increase In Revision 3), and Table 3-2 has been revised the plants baseline risk. What would prevent licensees to use al appropriately. There are no longer separate allowed CT (front-stop), overestimate the maintenance they can criteria for emergent and planned 66 NRC perform within the RICT. and then use the 'forced, unplanned ex maintenance.

On page 15 it is stated: 'Removal of a single SSC from service for longer than its front-stop CT, or simultaneous removal from serWce of multpe SSCs for bnger than the resulting most rinving frnt-stop CT, requkres an assessment using blended methods.' Does the phras simultaneous removal from service of multiple SSCs for longer than the resulting most The RMTS program guidance provided in this limiting front-stop cr imply use of (aX4)? An Investigation may report is Intended to be completely consistent be needed to determine whether there am any interface Issues with NUMARC 93-01, Revision 3 guidance for between (aX4) and RMTS program applied before and after the 10CFR50.65(a)(4). The report has been 67 NRC CT extension, respectively. rvised to clarify this isse . w The report has been revised to be morn consistent on these Issues, but we emphasize that this is a general gtidance document, not a regulatory requirements

-opage - 3" paragraph stetes that document Plants implementing RMTS programs wilt

'...The sce of the maintenance rule notedto address the application and scope of their plant.

Expiain why the required PRA levels ae different for the cases discussed in includes SSCs from plant Level 1 specific PRAs and CRMPs In their individual request e8 NRC the following ststenients. Cladfany Inconisistencies as 2ecessar. PRA6.... __________ submittals tothe NRC.

6sThereport has been revised to be more consisenit on thse Issues, but we emphasize that this is a general

• page .-3"1paragraph states that guidance document, not a regulatory requirements

'...For emnergent(unplannedi documsent Plants implementing RMTS programs will conditions PRA results should be need to address the application end scope of their plant-Explain why the required PRA levels are different for the cases disused In based on PRABwith minimum Levels specdiic PRAs end CRMPs in their individual request he following statements. Clarify any Inconsistencies as necessary, I ned2 attributes....o submttals to the NRC.

60 NRC _he report has been revised to be more consistent on these Issues, but we emphasize that ts isa general guidance document, not a bnguiatory requiremnxents document. Plants imiplementing RMTS programs will

- page 30.?' paragraph states need to address the application end scope of their plant-that ... specific PRAs end CRMPa in their indesoduai request requtd PRA lvesardifretforthcass di2sedin edeallynthissupportingPRAis Exawhyte 70 NRC the following statements. Caiyany Inconsistencies asnecessary, afuAscopeLevel2 or3 PRA..." subniittals to the NRC.

Page13 910U-are allPRA=peromed prior to ecumc excepemergent conditions? Risk assessmenrt guidance for emnergenit be condltlcn should Yes, weagree, and we feel that we have made this dear 71NRC consistent with (aX(4) the curment in~,~?' rport text Pages 14115 -what about 4pdates to Information. kfctxrki Industry Guijdance for inclusion of Industry experience has been NR xoerlence? Atwhat freatuencv should they be updated? _________ _________ dded tothe rettort tx a_________

11

RMTS RMG NRC Review Comment Resolution Responses 12MV#2003 Comment Comnment Supplementary Comment Supplementry Comment Supplenwnbtry Comment Number Source Co__w__t__

_ _ Text I Text 2 Text 3 Proposed Comment ResolutlonrResponse Atough hIsbgee r ndustry idance dowment, sssnma and l brr aamenot Acflotina nonof aid nItoa regbitery requ*arenta doc*ndnot we have completonamee be revised marny of to shot statenenta to now read completon lue or vondaston ti "e u r o_or_ 11 73 NRC _

The pWWM 0owspat WwM jibcW On SSCs VW rPM be car"Idered far Atugh dhisisa general industry gidance dooiment, ft lisk autaveert Te should ofto be ated InTS ban. The and not aregtalory requirements docunwnt, we have a gh og folt *...fl.l ru . aseehrblert_sopenay be revised many of dI -ahould statements to now read 74 NRC bited to the scope...or. "u 'alL" r '__

hIgera, c u n dlk Ii nw toled tob aUrge degree by fied abowed outge teehin ant STS andNRC rvw mid pprov of ly poo temporaryo xtensionr to com te Under tfie pptoach Po in w Rls Manag t Ot3de, conisa rieswoud be oW to a Wg degree by file e lisk manageent predeas. WI Yes, Tale 3-2 clearly presents heso ltil for an gtidncebe provd en how c

--- nafer indreport ft. ovta. RIS pro . Also, we have recmmeed in plantisassodated wlth extaen outagerue lder RMTS A ppaon fRG 1.174 end EPRI TR-1053l0 hi prrWm to ee a ny hOrese Is arpta mu Ifso,what monitorig end managing aggregate risk Plant-speu f anItIe aId utl al s beusd dete e phbl t RMTS progrn request u W address to" 7 Snc, 1innoiskmanagement?

why hisse in greater dtd ratn to bwW respective odthe keenage. perlbrotrnce in h rbk CRMPUand PRAS.

75 NRC nol7t?

12 I . I