ML050380357

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Enclosure 4: Risk Informed Technical Specification Task Force Risk Management Technical Specification Initiative Status
ML050380357
Person / Time
Issue date: 02/08/2005
From: Tjader T
NRC/NRR/DIPM/IROB
To: Bradley B
Nuclear Energy Institute
Tjader T., NRC/IROB, 415-1187
Shared Package
ML050380338 List:
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Download: ML050380357 (6)


Text

RISK INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)

RISK MANAGEMENT TECHNICAL SPECIFICATION INITIATIVE STATUS NEI RITSTF NEI Biff Bradley, 202 739-8083 WOG Jack Stringfellow, Southern Nuclear, 205 992-7037 CEOG Alan Hackerott, OPPD, 402 533-7276 Tony Pietrangelo, 202 739-8081 Jim Andrachek, Westinghouse, 412 374-5018 Gary Chung, SCE, 949 368-9431 EXCEL/

Jerry Andre, Westinghouse, 412 374-4723 Ray Schneider, CE, 860 731-6461 TSTF Donald Hoffman, 301 984-4400 EPRI Frank Rahn, 650 855-2037 BWOG Paul Infanger, Progress Energy, 352-563-4796 BWROG Rick Hill, GE, 408 925-5388 John Gaertner, 704 547-6169 S. Levinson, Framatome, 434 832-2768 Dusty Rhoads, Energy Northwest, 509 377-4298 Mike Kitlan, Duke, 980 373-8348 Don McCamy, TVA 256 729-4595 Page 1 of 7 1/31/2005 INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

RESPONSIBILITY TSTF NUMBER 1

Technical Specification Required Actions Preferred End States Industry revising implementation guidance for TSTF-422 and TSTF-423 to address NRC comments.

NRC/Industry met 1/30/04 on TSTF-422 and TSTF-423. The NRC/RITSTF agreed to resolutions for all the NRC comments.

A draft of the TSTF-422 implementation guidance document was provided to the NRC for comment in 6/04. NRC provided comments on 7/9/04 and a revised document has been developed to address these comments. A revised draft was submitted to the NRC on 9/21/04.

The NRC provided comments on the TSTF-422 implementation guidance on October 13. The RITSTF is revising the document to address the NRCs comments.

The WOG transmitted the final TSTF-422 implementation guidance to NEI on 12/2/04. NEI forwarded the document to the NRC in 12/04.

NRC plants to issue TSTF-422 Notice for Comment in March 2005.

TSTF-423 was submitted to the NRC on 8/12/03.

RITSTF provided draft responses to NRC comments on TSTF-423 at the 1/30/04 meeting.

The NRC provided comments on the TSTF-423 implementation guidance on October 13. The RITSTF revised the document to address the NRCs comments.

NRC plants to issue TSTF-423 Notice for Comment in March 2005.

TSTF-422 R0 (CEOG)

TSTF-423 R0 (BWROG)

TSTF-431 R0 (BWOG)

TSTF-432 R0 (WOG)

(Not created)

RITSTF INITIATIVE STATUS Page 2 of 7 1/31/2005 INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

RESPONSIBILITY TSTF NUMBER 1

Technical Specification Required Actions Preferred End States Industry and NRC developing implementation guidance for TSTF-422 and TSTF-423.

(continued)

BWOG Topical Report was submitted to NRC on 1/19/04. The NRC provided an RAI on 6/29/04.

The BWOG will respond in 2/05.

TSTF-431 was distributed to the BWOG and the RITSTF for review on 7/11/04.

TSTF-422 R0 (CEOG)

TSTF-423 R0 (BWROG)

TSTF-431 R0 (BWOG)

TSTF-432 R0 (WOG)

(Not created) 2 Missed Surveillances SR 3.0.3 TSTF-358, R6, has been approved and published for CLIIP adoption.

Initiative Complete.

TSTF-358 R6 3

Increase Flexibility in Mode Restraints LCO 3.0.4 TSTF-359, R9, has been approved and published for CLIIP adoption.

The final Implementation Guidance, NEI-03-10, was issued on September 5, 2003.

Initiative Complete.

Revisions are needed to clarify the implementation guidance. The TSTF will provide the proposed changes to NEI in the first quarter of 2005.

TSTF-359 R9 4a Individual Risk Informed Allowed Outage Times (AOTs)

Owners Groups (OGs) are pursuing generic Risk Informed AOT extensions through OG-specific Topicals and license amendments.

Ongoing.

TSTF-373R2 approved on 2/27/04.

TSTF-430R0 approved on 8/5/04.

TSTF-373 R2 (CEOG)

TSTF-409 R1 (CEOG)

TSTF-417 R0 (WOG)

TSTF-430 R0 (BWOG)

TSTF-439 R1 (ALL OG)

TSTF-446 R0 (WOG)

TSTF-454 R0 (BWROG)

RITSTF INITIATIVE STATUS Page 3 of 7 1/31/2005 INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

RESPONSIBILITY TSTF NUMBER 4b Risk Informed AOTs With Configuration Risk Management Program or Maintenance Rule Backstop Hope Creek, Fort Calhoun, South Texas Project, and Prairie Island have volunteered to develop pilot submittals.

Fort Calhoun and South Texas Project have submitted their pilots.

RITSTF will develop a White Paper to address the interface of the a.4 process to the Initiative 4b and Initiative 6 process to show the overlap and transition for ITS and non ITS plants and provide to NRC in 2/05.

NRC/RITSTF will meet 2/17-2/18, 2005 to discuss specifics of Initiative 4b RITSTF will provide revised deliverables for the RMG, CEOG and STP based on the 12/15/04 meeting and 2/17-2/18, 2005 meeting results.

The RITSTF has created an Initiative 4b Subgroup to coordinate responses to the NRC RAIs.

The RITSTF provided responses to the NRC and met to discuss these responses on 12/15/04.

NRC visited STP week of 1/18/05 to evaluate applications of Initiative 4b.

TSTF-424 R0 5a Relocate Surveillance Requirements Not Related to Safety Deterministic portion of Initiative 5 transferred to TSTF responsibility.

TSTF reviewing candidate SRs to be relocated.

TSTF will provide a TSTF to the NRC by 6/05.

None assigned

RITSTF INITIATIVE STATUS Page 4 of 7 1/31/2005 INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

RESPONSIBILITY TSTF NUMBER 5b Relocate Surveillance Test Intervals to Licensee Control RITSTF/BWROG/Pilot Plant will be applying the methodology and interfacing with the NRC on the issues in 2004.

NRC attended several Limerick IDP meetings to observe process.

The Limerick lead plant license amendment was submitted on June 11, 2004.

TSTF-425 was submitted to the NRC on 8/31/04.

A final draft of the methodology document was provided to the NRC in 09/04.

NEI will provide the formal Methodology Document to NRC by 2/4/05.

NRC is currently reviewing the Limerick LAR, TSTF-425, and the methodology document and plans to issue RAIs in 3/05.

TSTF-425 R0

RITSTF INITIATIVE STATUS Page 5 of 7 1/31/2005 INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

RESPONSIBILITY TSTF NUMBER 6a Modify LCO 3.0.3 Actions and Timing 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> On hold.

On hold for resolution of Initiative 6b and 6c to determine if Initiative 6a is required.

None assigned 6b Provide Conditions in the LCOs for Those Levels of Degradation Where No Condition Currently Exists to Preclude Entry Into LCO 3.0.3 NRC issued Safety Evaluation for Topical Report on 7/9/04.

TSTF-426 R0 was submitted to the NRC on 8/30/2004.

CEOG submitted revised version of Topical Report to address NRC RAIs in 10/03.

NRC issued Safety Evaluation for Topical Report on 7/9/04.

TSTF-426 R0 was submitted to the NRC on 8/30/04.

NRC provided an RAI on TSTF-426 on 11/13/04.

The TSTF will develop draft Implementation Guidance and provide responses to the NRCs RAIs by 3/31/05.

TSTF-426 R0 6c Provide Specific Times in the LCO For Those Conditions That Require Entry Into LCO 3.0.3 Immediately NRC issued Safety Evaluation for Topical Report on 7/9/04.

TSTF-426 R0 was submitted to the NRC on 8/30/2004.

CEOG submitted revised version of Topical Report to address NRC RAIs in 10/03.

NRC issued Safety Evaluation for Topical Report on 7/9/04.

TSTF-426 R0 was submitted to the NRC on 8/30/04.

NRC provided an RAI on TSTF-426 on 11/13/04.

The TSTF will develop draft Implementation Guidance and provide responses to the NRCs RAIs by 3/31/05.

TSTF-426 R0

RITSTF INITIATIVE STATUS Page 6 of 7 1/31/2005 INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

RESPONSIBILITY TSTF NUMBER 7a Impact of Non Technical Specification Design Features on Operability Requirements - Barriers TSTF-372, Rev. 4 submitted on 4/23/04.

TSTF-427 submitted on 3/4/03.

NRC provided comments on TSTF-427 on 11/13/04.

The NRC published the FRN Notice for Comment on TSTF-372 on 11/24/04.

The TSTF provided comments on the FRN Notice for Comment on 1/10/05.

The NRC is reviewing the TSTF comments and will work with the TSTF to revise the SE and issue the FRN Notice of Availability in 2/05.

NRC provided feedback on RITSTF responses on TSTF-427 in February 2004.

TSTF/RITSTF will delete the additions to the definition of OPERABILITY for TSTF-427 to address NRC concerns.

TSTF-427 implementation guidance was provided to the NRC on 09/21/04. NRC provided comments on the draft guidance on 10/13.

NRC provided an RAI on TSTF-427 on 11/13/04.

RITSTF will provide response to the NRCs RAIs by 3/31/05 and TSTF / RITSTF will provide a revision to TSTF-427 after completion of NRC review of the implementation guidance document and resolution of the NRCs questions.

TSTF-372 R4 TSTF-427 R0 7b Impact of Non TS Design Features on Operability Requirements - All other SSCs not in Technical Specifications A White Paper on the process to address this scope of SSCs is being developed.

RITSTF will develop a White Paper to outline the process to address this scope of SSCs by 3/05.

RITSTF/TSTF reviewed and has commented on the revised Operability guidance that will supersede the guidance distributed with GL 91-18.

RITSTF/TSTF will develop a TSTF and submit to NRC by 9/05.

None assigned

RITSTF INITIATIVE STATUS Page 7 of 7 1/31/2005 INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

RESPONSIBILITY TSTF NUMBER 8a Remove or Relocate Systems LCOs That Do Not Meet the 4 Criterion of 10 CFR 50.36 From Technical Specifications A White Paper on the application of the 10 CFR 50.36 criteria is being developed.

NEI 00-04 is being reviewed and will serve as the basis for Criterion 4 application.

RITSTF will develop a White 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 second quarter 2005.

None assigned 8b Modify 50.36 Rule to Permit Removal or Relocation of Non Risk Significant Systems out of Technical Specifications Requires Rulemaking RITSTF looking at coordinating Initiative 8b with longer term initiatives given the requirements for rulemaking.

Approach favored by NEI and NRC is making Criterion 4 a two way door (e.g., if it doesnt meet Criterion 4, Specification can be relocated even if it meets Criteria 1, 2, or 3).

Not applicable 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