ML052490186

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Risk Informed Technical Specification Task Force (RITSTF) Risk Management Technical Specification Initiative Status
ML052490186
Person / Time
Issue date: 09/06/2005
From:
NRC/NRR/DIPM/IROB
To:
Nuclear Energy Institute
Tjader T., NRC/IROB, 415-1187
Shared Package
ML052490174 List:
References
Download: ML052490186 (8)
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Text

RISK INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)

RISK MANAGEMENT TECHNICAL SPECIFICATION INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 1 Technical Specification

Required Actions Notice of Availability for on July 7, 2005.

Preferred End States TSTF-422 on July 7, 2005. TSTF-423 R0 (BWROG)

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

Notice for Comment for

  • BWROG working with NRC to address one issue TSTF-423 in September for the Implementation Guidance regarding time TSTF-432 R0 (WOG) 2005. to stay above 500 psig in MODE 3. (Not created)
  • The TSTF will submit the final TSTF-423 implementation guidance in September 2005.
  • NRC plans to issue TSTF-423 Notice for Comment in September 2005.
  • TSTF-431 was distributed to the BWOG and the RITSTF for review on 7/11/04.
  • BWOG Topical Report (BAW-2441) was submitted to NRC on 1/19/04. The NRC provided RAIs on 6/29/04. The BWOG responded to the RAIs in 2/05.
  • NRC is currently reviewing the BWOG RAI responses.
  • NRC plans to issue Notice for Comment for TSTF 431 by 12/05.
  • WOG plans to submit their Topical in 9/05.

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 TSTF Donald Hoffman, EXCEL 301 984-4400 Jerry Andre, Westinghouse 412 374-4723 Ray Schneider, CE 860 731-6461 EPRI Frank Rahn 650 855-2037 BWOG Paul Infanger, Progress Energy 352 563-4796 BWROG Fred Emerson, GE John Gaertner 704 547-6169 Stanley Levinson, Framatome 434 832-2768 Dusty Rhoads, Energy Northwest 509 377-4298 Mike Kitlan, Duke 980 373-8348 Page 1 of 8 8/17/2005

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

  • TSTF and RITSTF will issue implementation guidance in the fourth quarter of 2005.

3 Increase Flexibility in

  • Initiative Complete. TSTF-359 R9 Mode Restraints LCO approved and published for 3.0.4 CLIIP adoption.
  • Revisions are needed to clarify the implementation guidance. The TSTF and RITSTF
  • The final Implementation will revise and reissue the implementation Guidance, NEI-03-10, was guidance in the fourth quarter of 2005.

issued on September 5, 2003.

4a Individual Risk

  • Owners Groups (OGs) are

Informed Completion pursuing generic Risk

  • TSTF-373R2 approved on 2/27/04.

Times Informed Completion Time

  • TSTF-430R0 approved on 8/5/04. TSTF-409 R1 (CEOG) extensions through OG-
  • NRC issued the TSTF-454 FRN Notice for specific Topicals and Comment on 5/25/05. The TSTF provided TSTF-417 R0 (WOG) license amendments. comments on 7/25/05. The TSTF is preparing a revision to TSTF-454 to reflect the NRC- TSTF-430 R0 (BWOG) approved Topical Report.
  • TSTF-439R2 was submitted to the NRC on TSTF-439 R2 (ALL OG) 6/20/05.

Notice for Comment in August 2005.

  • The NRC expects to complete their review of the TSTF-454 R0 (BWROG)

Topical Reports that support TSTF-417R0 and TSTF-446R0 in August 2005. Review of the Travelers will follow approval of the Topical Reports.

Page 2 of 8 8/17/2005

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 4b Risk Informed

  • Fort Calhoun, South Texas
  • RITSTF will develop a White Paper to address the TSTF-424 R0 Completion Times Project, and Prairie Island interface of the a.4 process to the Initiative 4b and With Configuration have volunteered to develop Initiative 6 process to show the overlap and Risk Management pilot submittals. transition for ITS and non ITS plants and will Program or provide to NRC in 4/05.

Maintenance Rule

  • Fort Calhoun and South Backstop Texas Project have
  • NRC provided 3 separate RAIs in 8/04 to NEI.

submitted their pilots.

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

resolve the NRCs comments on the Risk

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

the STP submittal, and the Traveler.

  • NRC visited STP week of 1/18/05 to evaluate applications of Initiative 4b.
  • NRC and RITSTF met 3/17-18/05 and 5/3-5/4, 2005 to discuss policy issues. NRC will issue meeting summaries of these meetings.
  • NRC will provide comments on the RMTS Guidelines by late 9/05.
  • The RITSTF has revised the draft Risk-Managed Technical Specifications (RMTS) Guidelines document incorporating the results of the discussions with the NRC. The revised draft RMTS document was provided to the NRC at the August RITSTF/NRC meeting.
  • NRC will provide comments on the draft RMTS to RITSTF in 9/05.

5a Relocate Surveillance

  • Deterministic portion of
  • TSTF reviewing candidate SRs to be relocated. None assigned Requirements Not Initiative 5 transferred to Related to Safety TSTF responsibility.
  • TSTF will provide a Traveler to the NRC by 6/06.

Page 3 of 8 8/17/2005

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 5b Relocate Surveillance

  • RITSTF/BWROG/Pilot
  • The Limerick lead plant license amendment was TSTF-425 R0 Test Intervals to Plant will be applying the submitted on 6/11/04.

Licensee Control methodology and interfacing with the NRC

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

on the issues in 2004.

  • NEI provided the formal methodology document to the NRC on 2/3/05.
  • NRC reviewed the Limerick LAR, TSTF-425, and the methodology document and issued RAIs 4/12/05 to the RITSTF.
  • A separate subcommittee was formed by the RITSTF to respond to the NRCs RAIs.
  • The 5b subcommittee met with the NRC on June 3 to discuss the RAI responses.
  • The RITSTF plans to respond to the RAIs in September, 2005.

6a Modify LCO 3.0.3

  • On hold.
  • On hold for resolution of Initiative 6b and 6c to None assigned Actions and Timing 1 determine if Initiative 6a is required.

hour - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Page 4 of 8 8/17/2005

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 6b Provide Conditions in

  • NRC issued Safety
  • CEOG submitted revised version of Topical TSTF-426 R0 the LCOs for Those Evaluation for Topical Report to address NRC RAIs in 10/03.

Levels of Degradation Report on 7/9/04.

Where No Condition

  • NRC issued Safety Evaluation for Topical Report Currently Exists to

Preclude Entry Into submitted to the NRC on LCO 3.0.3 8/30/04.

  • TSTF-426 R0 was submitted to the NRC on 8/30/04.
  • The TSTF has developed Implementation Guidance and will provide it to the NRC in 8/05.
  • The TSTF provided responses to the NRCs RAIs on 4/27/05.
  • The TSTF 426 Implementation Guidance was provided to NRC in early 8/05.
  • NRC plans to issue the Notice for Comment in September 2005.

Page 5 of 8 8/17/2005

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 6c Provide Specific Times

  • NRC issued Safety
  • CEOG submitted revised version of Topical TSTF-426 R0 in the LCO For Those Evaluation for Topical Report to address NRC RAIs in 10/03.

Conditions That Report on 7/9/04.

Require Entry Into

  • NRC issued Safety Evaluation for Topical Report LCO 3.0.3 Immediately

submitted to the NRC on 8/30/04.

  • TSTF-426 R0 was submitted to the NRC on 8/30/04.
  • The TSTF has developed Implementation Guidance and will provide it to the NRC in 8/05.
  • The TSTF provided responses to the NRCs RAIs on 4/27/05.
  • The TSTF 426 Implementation Guidance was provided to NRC in early 8/05.

NRC plans to issue the Notice for Comment in September 2005.

Page 6 of 8 8/17/2005

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

  • The NRC issued the FRN
  • The NRC published the FRN Notice of TSTF-372 R4 Technical Specification Notice of Availability for Availability for TSTF-372 on 5/4/05.

Design Features on TSTF-372, Rev. 4 on TSTF-427 R0 Operability 5/4/05.

  • NRC provided feedback on RITSTF responses on Requirements - Barriers TSTF-427 in February 2004.
  • TSTF will delete the additions to the definition of implementation guidance. 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 10/13/04.
  • RITSTF provided responses to the NRCs RAIs on 3/23/05.
  • The NRC provided additional questions on the TSTF-427 implementation guidance in a letter dated June 2, 2005. RITSTF to respond.
  • Members of the TSTF & RITSTF met with the NRC on 7/28/05 to discuss NRC comments. The TSTF is preparing a revision of TSTF-427 to be submitted to the NRC in October 2005.
  • There was discussion of the LCO 3.0.9 that requires revision. The RITSTF will develop changes to LCO 3.0.9 and TSTF 427 Implementation Guidance to address the barrier that affects both trains of a system and the emergent condition of 1 barrier that affects 1 train and the second train becomes inoperable for another reason.
  • The revised implementation guidance and revised TSTF-427 will be distributed to the RITSTF for review in September for submittal to the NRC in October 2005.

Page 7 of 8 8/17/2005

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

  • A White Paper on the
  • RITSTF will develop a White Paper to outline the None assigned Design Features on process to address this scope process to address this scope of SSCs in 9/05.

Operability of SSCs is being developed.

Requirements - All

  • RITSTF/TSTF reviewed and has commented on other SSCs not in the revised Operability guidance that will Technical supersede the guidance distributed with GL 91-18.

Specifications

  • RITSTF/TSTF will develop a TSTF and submit to NRC by 6/06.

8a Remove or Relocate

  • A White Paper on the
  • NEI 00-04 is being reviewed and will serve as the None assigned Systems LCOs That Do application of the 10 CFR basis for Criterion 4 application.

Not Meet the 4 50.36 criteria is being Criterion of 10 CFR developed.

  • RITSTF will develop a White Paper to outline the 50.36 From Technical guidance and methodology based on NEI 00-04 Specifications 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 fourth quarter 2005.

8b Modify 50.36 Rule to

  • Requires Rulemaking
  • RITSTF looking at coordinating Initiative 8b with Not applicable Permit Removal or longer term initiatives given the requirements for Relocation of Non Risk rulemaking.

Significant Systems out of Technical

  • Approach favored by NEI and NRC is making Specifications 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).

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 Page 8 of 8 8/17/2005

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