ML090160113
| ML090160113 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 01/15/2009 |
| From: | - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| Peter Tam, NRR/DORL 415-1451 | |
| References | |
| TAC ME0247 | |
| Download: ML090160113 (1) | |
Text
Kewaunee Conversion Pre-Submittal Meeting IT8B Topics for Discussion Based on internallTSB discussions of lessons learned from previous Tech Spec Conversions including Davis Bessie (18-19 Dec. 2008)
Preparation of Submittal
- The completeness and complexity (or simplicity) of the submittal affects evaluation process
- Submittal letter must confirm that the CD is equivalent to hard copy
- STS 3.0 is the latest version and basis for conversion, not 3.1
---t List all TSTF's adopted in which all aspects of the TSTF were not followed (l.e.
deviations, not adopting commitments, etc)
- All submittals should state if a commitment or license condition has been added modified or deleted
- Identification of Beyond Scope Items (BSI)
---t Current Licensing Basis
---t Definition
-+ Review of CLB during Conversion evaluation Review Process Overview and Lessons Learned
- Describe typical stages and schedule
- Definition and impact of "Beyond Scope Items" (BSI)
---t They are generally characterized as changes that differ from both the existing technical specifications and the improved STS
---t As defined in NRC Administrative Letter 96-04, BSls are those changes to the technical specifications that are not directly related to the conversion amendment.
---t NEI 96-06, Improved Technical Specifications Conversion Guidance, similarly identifies BSls as changes, such as plant-specific risk-based changes and power uprates, which are considered beyond the scope of the ITS conversion application and therefore may result in delays in... approval of the application.
- Use of Bases during review
- Use of RAl's during review
- Use of Current Licensing Basis during review
- Items requiring Technical Branch Review
---t List of examples Other Items
- Plant responsiveness
---t Effect of refueling outages during evaluation period?.
---t Timely and thorough
- Applicability of precedent
- Ongoing reviews of TSTF's can impact conversion
- Use of Excel Services Database
---t Used for both informal questions and information requests
---t Unresolved issues may elevate quickly to RAI's