ML091630177

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Technical Specification Task Force Presentation for Meeting to Discuss Status of Current and Planned TSTF Travelers, and Process and Administrative Issues of Mutual Interest
ML091630177
Person / Time
Site: Technical Specifications Task Force
Issue date: 06/04/2009
From:
Technical Specifications Task Force
To:
Office of Nuclear Reactor Regulation
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Download: ML091630177 (38)


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6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF/NRC Meeting June 4, 2009 1

Technical Specifications Task Force TSTF A Joint Owners Group Activity Administrative Issues 2

1

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF Process Issues 3

Technical Specifications Task Force TSTF A Joint Owners Group Activity Traveler Status Recent Development are in yellow.

4 2

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity Traveler Activities 6/1/2009 Description 2006 2007 2008 2009 Travelers 8 9 1 1 Approved Notices of 6 9 1 1 Availability Published Notices for 9 5 1 0 Comment Published NRC Letters L 28 27 13 7 (RAIs, etc.)

TSTF Letters 35 31 22 13 5

Technical Specifications Task Force TSTF A Joint Owners Group Activity Travelers Scheduled to be Approved in 2009

1. TSTF425, "Relocate Surveillance Frequencies to Licensee Control RITSTF Initiative 5b" (NoA scheduled midJune)
2. TSTF446, "Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP15791)" (NfC scheduled in June)
3. TSTF500, "DC Electrical Rewrite Update to TSTF360" (Sending revision but NfC drafted)
4. TSTF501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control" (NfC scheduled in June)
5. TSTF513,, "Revise PWR Operability p y Requirements q and Actions for RCS Leakage Instrumentation"
6. TSTF514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" 6

3

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF425, Relocate Surveillance Frequencies to Licensee Control RITSTF Initiative 5b (All)

High Priority 2009 Opportunity Date Event 6/11/2004 Limerick lead plant amendment submitted.

8/31/2004 TSTF submits TSTF425, Rev. 0. Only applicable to BWRs.

2/3/2005 NEI submits NEI 0410, "RiskInformed Technical Specifications Initiative 5b RiskInformed Method for Control of Surveillance Frequencies."

9/28/2006 NRC approves NEI 0410, 04 10 and the Limerick lead plant license amendment.

amendment 2/5/2007 NRC closes the TAC and stops review of TSTF425, Revision 0 pending submittal of NEI 0410 methodology document revision addressing the applicability to PWRs and Staggered Test Basis Frequencies.

(continued) 7 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF425, Relocate Surveillance Frequencies to Licensee Control RITSTF Initiative 5b (All)

High Priority 2009 Opportunity Date Event 4/19/2007 NEI 0410, Rev. 1, submitted addressing Staggered Test Basis Frequencies.

4/20/2007 TSTF425, Rev. 1, submitted referencing NEI 0410, Rev. 1, and including all ISTS NUREGs.

6/7/2007 NRC issues Acceptance and Review Milestone letter for TSTF425, Rev. 1.

RAIs scheduled for 10/31/2007.

Notice of Availability scheduled for 6/28/2008.

9/19/2007 NRC approval of NEI 0410, Rev. 1 10/2/2007 NRC issues RAI on TSTF425, Rev. 1.

(continued) 8 4

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF425, Relocate Surveillance Frequencies to Licensee Control RITSTF Initiative 5b Date Event 1/17/2008 TSTF responds to RAI and submits TSTF425, Rev. 2.

3/31/2008 NRC issues Acceptance and Schedule Milestone letter for Rev. 2.

Notice for Comment scheduled for 5/28/2008.

Notice of Availability scheduled for 8/28/2008.

7/16/2008 The TSTF was informed that the NRC is resolving comments from the OGC and the Notice for Comment is expected to be issued by the end of July.

12/5/2008 NRC issues Notice for Comment 1/5/2009 TSTF responds to the Notice for Comment (continued) 9 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF425, Relocate Surveillance Frequencies to Licensee Control RITSTF Initiative 5b Date Event 1/30/2009 TSTF/NRC discuss TSTF comments on Notice for Comment.

3/18/2009 TSTF submits TSTF425, Rev. 3, to conform with the NRC changes in the draft Safety Evaluation.

5/15/2009 NRC issues Temporary Inspection Instruction 2515/178, "Risk Management Technical Specifications , Initiative 5b, Surveillance Frequency Control Program" 5/30/2009 NRC to issue Notice of Availability for TSTF425.

10 5

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF426, Revise or Add Actions to Preclude Entry into LCO 3.0.3 RITSTF Initiatives 6b & 6c (CE) Medium Priority Date Event 10/3/2003 WCAP16125, Rev. 0, "Justification for RiskInformed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown," submitted to NRC for review.

7/9/2004 NRC approves WCAP16125, Rev. 0.

8/30/2004 TSTF426, Rev. 0, submitted. Justification based on WCAP16125, Rev. 0.

11/13/2004 NRC provides RAIs on TSTF426, Rev. 0 4/27/2005 TSTF responds to NRC RAI.

(continued) 11 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF426, Revise or Add Actions to Preclude Entry into LCO 3.0.3 RITSTF Initiatives 6b & 6c Date Event 7/20/2006 NRC issues the Notice for Comment for TSTF426, Rev. 0.

8/21/2006 TSTF responds to Notice for Comment.

11/27/2006 NRC requests revisions to TSTF426, Rev. 0 and to WCAP16125.

1/18/2007 A public meeting with the NRC is held to discuss WCAP WCAP16125 16125 and TSTF426.

TSTF 426 The industry agrees to revise TSTF426 and WCAP16125.

2/5/2007 NRC sends letter to TSTF closing the TAC and stopping review for TSTF426, Rev. 0 (continued) 12 6

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF426, Revise or Add Actions to Preclude Entry into LCO 3.0.3 RITSTF Initiatives 6b & 6c Date Event 1/7/2008 The PWROG submits WCAP16125, Rev. 1, to address NRC comments.

7/22/2008 The NRC provides an Acceptance and Schedule Milestone letter for WCAP 16125, Rev. 1.

8/5/2008 The TSTF submits TSTF426, Rev. 1, addressing NRC comments and referencing WCAP16125, Rev. 1.

1/27/2009 NRC provides RAI on WCAP WCAP16125 16125 (continued) 13 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF426, Revise or Add Actions to Preclude Entry into LCO 3.0.3 RITSTF Initiatives 6b & 6c Date Event 1/27/2009 NRC provides RAI on WCAP16125 5/8/2009 PWROG submits RAI response revised WCAP16125 5/27/2009 TSTF distributes revised TSTF426 for industry review. Revised to reflect revised WCAP16125.

5/27/2009 PWROG informs TSTF that NRC has provided comments on the WCAP and will not accept some of the changes in TSTF TSTF426.

426.

Pending Awaiting NRC formal RAI on WCAP16125 prior to revising TSTF426.

14 7

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF431, Change in Technical Specifications End States (BAW2441) (B&W) High Priority Date Event 1/19/2004 The B&WOG submits BAW2441, Rev. 2, "Risk Informed Justification for LCO EndState Changes," to the NRC for review.

8/25/2006 The NRC approves BAW2441, Rev. 2.

11/3/2006 The TSTF submits TSTF431, Rev. 1.

(TSTF431, Rev. 0, was not submitted for NRC review as it was superseded by the NRC's approval of BAW2441, Rev. 2.)

12/5/2005 The NRC issues a letter to the TSTF granting a fee exemption for TSTF431.

3/16/07 The NRC provides a letter with Schedule Milestones.

RAIs scheduled for 4/15/2007 Notice of Availability scheduled for 12/31/2007.

(continued) 15 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF431, Change in Technical Specifications End States (BAW2441)

Date Event 5/3/2007 The NRC provides a Request for Additional Information.

7/9/2007 The TSTF responds to the NRC's RAI.

7/12/2007 In a teleconference, the NRC technical reviewer stated that he would not accept a change to the Containment Specification end state regardless of the NRC approval of the justification for the change in BAW2441.

7/13/2007 After conferring with the B&W plants, the TSTF submits TSTF431, Rev. 2, removing the change to the Containment Specification end state change.

11/3/2007 The NRC publishes the Notice for Comment for TSTF431, Rev. 2.

(continued) 16 8

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF431, Change in Technical Specifications End States (BAW2441)

Date Event 12/21/2007 The TSTF provided comments on the Notice for Comment by email.

3/25/2008 The NRC informed the TSTF that the scheduled date for the Notice of Availability of 4/11/2008 would be delayed due to concerns regarding inclusion of Tier 2 commitments in the Technical Specifications and acceptability of RITSTF Initiative 1 changes.

1/30/2009 The NRC to provide a letter to the TSTF requesting revision of TSTF431 to address applicability of LCO 3.0.4.

304 Pending TSTF to revise TSTF431 following receipt of NRC letter on Initiative 1 Travelers.

17 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF446, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP15791)

High Priority 2009 Opportunity Date Event 6/6/2002 The WOG submits WCAP15791, Rev. 0, "RiskInformed Evaluation of Extensions to Containment Isolation Valve Completion Times" 10/25/2002 The TSTF submits TSTF446, Rev. 0, "Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP15791)"

5/6/2004 The WOG submits WCAP15791, Rev. 1.

1/31/2005 The TSTF submits TSTF446, TSTF 446 Rev Rev. 1, 1 to address responses to NRC RAI's on WCAP15791.

3/10/2006 The NRC approves WCAP15791, Rev. 1.

(continued) 18 9

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF446, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP15791)

Date Event 9/28/2006 The NRC approves the Wolf Creek lead plant license amendment.

1/11/2007 The TSTF submits TSTF446, Rev. 2, containing changes to be consistent with WCAP15791 and to incorporate lessonslearned from the lead plant amendment.

5/29/2007 The NRC sends a letter to the TSTF stating that they are halting their review of TSTF446 pending receipt of a revised WCAP15791 incorporating changes consistent with the draft Safety Evaluation.

Evaluation 6/12/2007 The TSTF submits a letter to the NRC requesting restart of the TSTF446, Rev.

2 review based on submittal of the revised WCAP15791 on May 25, 2007.

(continued) 19 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF446, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP15791)

Date Event 9/14/2007 The NRC provides and Acceptance and Schedule Milestone letter on TSTF 446, Rev. 2.

RAIs scheduled to be provided on 10/12/2007.

Notice of Availability scheduled to be published on 4/30/2008.

10/11/2007 The NRC provided comments and questions on TSTF446 during a teleconference.

2/19/2008 The TSTF submitted TSTF446, Rev. 2, addressing the NRC's comments.

2/25/2008 The NRC notified the TSTF by email of the revised Schedule Milestones.

The Notice for Comment is scheduled to be published on 3/25/2008.

The Notice of Availability is scheduled to be published on 6/27/2008.

(continued) 20 10

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF446, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP15791)

Date Event 4/15/2008 The NRC notified the TSTF by email that the revised Notice for Comment scheduled date is 5/2/2008. The Notice of Availability date remains 6/27/2008.

7/8/2008 The NRC notified by the TSTF by telephone that the NRC ITSB is resolving comments from the NRC OGC. OGC has objections to issuing the Traveler under the CLIIP.

10/29/2008 The NRC notified the TSTF by letter that TSTF446 will be processed following the Notice for Comment for TSTF TSTF425:

425:

Scheduled Date for Notice for Comment: 12/31/2008 Scheduled Date for Notice of Availability: 3/30/2009 1/30/2009 At the 1/30/2009 TSTF/NRC meeting, the TSTF provided comments on the Notice of Availability for TSTF498 (the B&W CIV CT extension Traveler). NRC to revise the TSTF446 Notice for Comment to reflect the TSTF comments.

(continued) 21 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF446, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP15791)

Date Event 1/12/2009 Scheduled date for Notice for Comment is 2/7/2009 2/9/2009 Scheduled date for Notice for Comment is 2/27/2009 3/9/2009 Scheduled date for Notice for Comment is 3/31/2009 4/6/2009 Scheduled date for Notice for Comment is 4/30/2009 5/11/2009 Scheduled date for Notice for Comment is 5/30/2009.

22 11

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF493, Clarify Application of Setpoint Methodology for LSSS Functions (All) High Priority Date Event 9/27/2002 The NRC issued an RAI for Ginna related to a license amendment to revise the Safety Limits and instrument setpoints. The RAI questioned the methodology described ISA 67.04, Method 3, used by Ginna.

11/20/2002 Several meetings and conference calls were held between the industry and 8/13/2003 the NRC discussing the use of ISA 67.04, Method 3.

10/8/2003 At a public meeting with the NRC, the NRC identified a secondary concern on the acceptable use of the Allowable Value to act as the LSSS as required byy 10 CFR 50.36(c)(1)(ii)(A).

( )( )( )( ) The NRC considers the LSSS issue to be separatep from the technical concern with Method 3. The NRC agreed to provide a written description of their concern (including basis) within approximately 30 days.

(continued) 23 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF493, Clarify Application of Setpoint Methodology for LSSS Functions Date Event 6/17/2004 The NRC issues "Problem Statement on the Use of Instrumentation, Systems and Automation Society (ISA) Standard ISA 67.04 Part II. 'Methodology For The Determination Of Setpoints For Nuclear SafetyRelated Instrumentation.

Method 3."

7/26/2004 At a public meeting with the NRC, the NRR Director of Engineering states that the NRC considers plants that use Method 3 to be safe but the issue of what constitutes compliance with the definition of LSSS in 10 CFR 50.36 remains. The NRC has not determined the next action to be taken.

7/27/2004 The industry initiates technical studies. Public meetings are held and letters 1/27/2006 are exchanged between the NEI SMTP and the NRC to establish the NRC's position and an acceptable solution.

1/27/2006 Based on the results of the meetings and letters, the TSTF submits TSTF493, Rev. 0, to the NRC.

(continued) 24 12

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF493, Clarify Application of Setpoint Methodology for LSSS Functions Date Event 3/2/2006 The NRC grants the fee waiver for TSTF493.

3/22/2006 The NRC provides RAIs on an electronic comment forum being tested by the NRC and the industry.

8/24/2006 The NRC publishes RIS 200617, "NRC Staff Position On The Requirements Of 10 CFR 50.36, 'Technical Specifications,' Regarding Limiting Safety System Settings During Periodic Testing And Calibration Of Instrument Channels.

Channels "

This reiterates the scope of functions to be addressed.

10/2/2006 The TSTF submits TSTF493, Rev. 1, addressing the NRC's RAIs and additional items identified in discussions held with the NRC.

(continued) 25 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF493, Clarify Application of Setpoint Methodology for LSSS Functions Date Event 11/8/2006 The NRC provides RAIs on TSTF493, Rev. 1.

4/16/2007 The TSTF submits TSTF493, Rev. 2.

5/24/2007 The NRC provides an Acceptance and Schedule Milestone letter.

RAIs are scheduled to be provided by 8/1/2007.

The Notice of Availability was scheduled to be published on 4/15/2008.

7/25/2007 The NRC provides RAIs and proposed Bases changes.

1/18/2008 The TSTF submits TSTF493, Rev. 3. In letters dated 10/31/2007 and 12/19/2007, the TSTF extended the response date to provide time for additional industry review.

(continued) 26 13

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF493, Clarify Application of Setpoint Methodology for LSSS Functions Date Event 3/17/2008 The NRC provides an Acceptance and Schedule Milestone letter.

The Notice for Comment is scheduled to be issued on 6/13/2008.

The Notice of Availability is scheduled to be issued on 9/12/2008.

6/10/2008 The NRC provided a letter to the TSTF that they will require additional time to review TSTF493 and will provide new target dates in the August 2008 time frame.

11/4/2008 The NRC responded to the TSTF's 1/18/08 RAI response, summarizing the NRC s issues and preferred resolution NRC's 1/8/2009 At a meeting between the NRC and the Owners Group chairmen, an agreement was reached on the resolution of the outstanding issues associated with TSTF493.

2/23/2009 The TSTF responded to the NRC's 11/4/08 letter on TSTF493 scope confirming the agreements reached at the 1/8/2009 meeting.

(continued) 27 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF493, Clarify Application of Setpoint Methodology for LSSS Functions Date Event 3/9/2009 NRC responded by letter to the TSTF accepting the proposed approach to resolve TSTF493.

7/31/2009 TSTF to submit TSTF493, Rev. 4.

The TSTF and NRC have met multiple times and exchanged drafts to reach agreement on the implementation of the proposed approach.

28 14

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF500, DC Electrical Rewrite Update to TSTF360 (All)

High Priority 2009 Opportunity Date Event 12/18/2000 The NRC approves TSTF360, "DC Electrical Rewrite."

4/11/2006 The NRC provides a letter to the TSTF describing their concerns with TSTF 360. The TSTF requested the letter because of difficulties experienced by licensees during plantspecific requests of TSTF360.

7/12/2006 A public meeting with the NRC was held to discuss the NRC's concerns and the proposed remedies.

12/19/2006 The NRC approves the LaSalle TSTF360 adoption amendment. At the recommendation of the NRC, the TSTF utilized the LaSalle Safety Evaluation as the basis for developing TSTF500.

(continued) 29 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF500, DC Electrical Rewrite Update to TSTF360 Date Event 8/31/2007 The TSTF submits TSTF500, Rev. 0.

10/1/2007 The NRC denies the TSTF request for a review fee exemption for TSTF500.

10/29/2007 The NRC provides a letter accepting TSTF500 but halting their review pending acceptance of review fees by the Industry.

10/31/2007 The TSTF provides a letter to the NRC accepting review fees for TSTF500.

(continued) 30 15

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF500, DC Electrical Rewrite Update to TSTF360 Date Event 3/6/2008 The NRC provided Schedule Milestones by email.

RAIs are scheduled to be provided by 04/15/2008.

The Notice for Comment is scheduled to be published on 08/15/2008.

The Notice of Availability is scheduled to be published on 11/15/2008.

3/11/2008 Following discussions with the NRC, the TSTF provided a draft Model Application for TSTF500.

6/4/2008 The NRC provided RAIs on TSTF500.

8/18/2008 TSTF provides responses to the TSTF500 RAIs.

(continued) 31 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF500, DC Electrical Rewrite Update to TSTF360 Date Event 9/11/2008 TSTF and NRC met to discuss NRC questions.

11/5/2008 TSTF500, Rev. 1, submitted.

1/12/2009 Scheduled date for Notice for Comment is 1/26/2009 2/9/2009 Scheduled date for Notice for Comment is 2/26/2009 3/9/2009 Scheduled date for Notice for Comment is 4/1/2009 (continued) 32 16

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF500, DC Electrical Rewrite Update to TSTF360 Date Event 4/1/2009 NRC informed the TSTF that a revision to TSTF500 will be required to reference IEEE4502002 and RG 1.129, Rev. 2.

5/1/2009 A final draft of the proposed TSTF500 program is provided to NRC following exchange of several drafts.

Awaiting Following feedback from NRC on acceptability of the proposed Program, NRC TSTF to submit a revision to TSTF500.

p response 33 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF501, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control Medium Priority 2009 Opportunity Date Event 7/20/2007 The TSTF submits TSTF501.

9/24/2007 The NRC provides an Acceptance and Schedule Milestone letter.

RAIs are scheduled to be provided on 11/20/2007.

The Notice of Availability is scheduled to be published on 7/18/2008.

12/13/2007 The NRC provides an RAI on TSTF501.

3/6/2008 The TSTF responds to the NRC's RAI.

(continued) 34 17

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF501, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control Date Event 3/6/2008 Following discussions with the industry and the NRC, the TSTF submits a letter to the NRC requesting a full or partial fee exemption for TSTF501.

4/10/2008 The NRC denies the TSTF's fee exemption request.

5/5/2008 The NRC provided a second RAI and revised Schedule Milestones.

The Notice for Comment is scheduled to be published on 10/1/2008.

The Notice of Availability is scheduled to be published on 12/3/2008.

9/17/2008 TSTF responded to the NRC's RAI RAI.

12/23/2008 In a teleconference to address NRC questions, TSTF agreed to submit a revision to TSTF501 that expanded the Bases.

(continued) 35 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF501, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control Date Event 2/20/2009 TSTF501, Rev. 1, submitted to NRC.

3/9/2009 Scheduled date for Notice for Comment is 3/31/2009 4/6/2009 Scheduled date for Notice for Comment is 4/30/2009 5/8/2009 Scheduled date for Notice for Comment is 5/30/2009 36 18

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF507, CLIIP Traveler to Increase Standardization Low Priority Date Event 7/3/2008 The TSTF submitted TSTF507, Rev. 0.

12/23/2008 The NRC stated they would send a letter to the TSTF detailing their concerns with the scope of the Traveler.

5/8/2009 NRC stated that the letter had not been started.

TSTF will withdraw TSTF-507.

TSTF requests that NRC close the TAC for this Traveler.

TSTF requests that NRC informally (verbal, e-mail) provide the list of Travelers in TSTF-507 that would be expensive to include. May request a meeting to discuss a future submittal.

37 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF508, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF448 Implementation Medium Priority Date Event 7/3/2008 The TSTF submitted TSTF508, Rev. 0.

10/7/2008 NRC provided acceptance and schedule letter dated October 7, 2008.

Scheduled date for RIAs: 11/17/2008 Scheduled date for Notice for Comment: 4/10/2009 Scheduled date for Notice of Availability: 7/9/2009 11/19/2008 NRC informed TSTF that there were no RAIs on TSTF508.

2/26/2009 In a conference call requested by NRC to discuss TSTF508 , the NRC questioned the basis for applicability of the change to shutdown conditions.

NRC to send a written RAI.

4/17/2009 NRC provided an RAI on TSTF508.

(continued) 38 19

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF508, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF448 Implementation Date Event 6/30/2009 TSTF scheduled to respond to NRC RAI and provide a revised Traveler by 6/30/2009.

39 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF510, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection Medium Priority Date Event 3/26/2009 The TSTF submitted TSTF510, Rev. 0, and a request for waiver of review fees.

5/8/2009 Review on hold pending a decision on fee waiver. NRC stated that they had not yet processed the fee waiver request.

40 20

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF512, Revise SR 3.0.3 to Address SRs that Cannot be Performed or are Not Met High Priority Date Event 10/14/2008 The TSTF submitted TSTF512, Rev. 0.

5/1/2009 NRC provided a letter to the TSTF stating that there was insufficient information to support review of TSTF512.

12/18/2009 TSTF will revise and resubmit TSTF512 by the end of 2009 to provide the requested additional justification for the issue of SRs that have never been performed and SRs that cannot be performed within the specified Frequency.

41 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF513, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation Medium Priority 2009 Opportunity Date Event 11/14/2009 The TSTF submitted TSTF513, Rev. 0 1/12/2009 The NRC requested that the TSTF expand the TSTF513 Bases to clarify the Operability requirements.

2/18/2009 The TSTF submitted TSTF513, Revision 1, and TSTF514, Revision 0, and a fee exemption request for TSTF513 and TSTF514.

3/27/2009 The NRC grants the fee waiver for TSTF513 and TSTF513.

5/6/2009 The NRC transmitted an RAI on TSTF513.

(continued) 42 21

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF513, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation Date Event 5/28/2009 Teleconference between the NRC and TSTF to clarify the RAIs.

6/30/2009 TSTF scheduled to submit the RAI response and TSTF513, Rev. 2, by 6/30/2009. (Date dependent on receipt of the TSTF514 RAI.)

43 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF514, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation Medium Priority 2009 Opportunity Date Event 2/18/2009 The TSTF submitted TSTF513, Revision 1, and TSTF514, Revision 0, and a fee exemption request for TSTF513 and TSTF514.

3/27/2009 The NRC grants the fee waiver for TSTF513 and TSTF513.

5/8/2009 NRC preparing an RAI on TSTF514. Scheduled to be sent midMay, 2009.

44 22

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF515, Revise PostAccident Monitoring Instrumentation based on Reg Guide 1.97, Rev. 4 and NEDO33349 Medium Priority Date Event 1/20/2009 The TSTF submitted TSTF515, Rev. 0.

5/8/2009 The NRC requested a teleconference to discuss TSTF515. NRC to provide nature of questions to facilitate arrangement of call.

Pending A teleconference will be arranged once the NRC informs the TSTF of the nature of the questions.

45 Technical Specifications Task Force TSTF A Joint Owners Group Activity CLIIP Status 46 23

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity CLIIP Survey

  • TSTF to update the CLIIP adoption status in th thi the third d Quarter Q t off 2009 andd plan l tto update d t annually thereafter.
  • Will share results with NRC at the first meeting of each year.

(continued) 47 Technical Specifications Task Force TSTF A Joint Owners Group Activity Status of NRC letter clarifying RIS 200006

  • TSTF withdraws request for NRC to provide a letter.

48 24

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity Issues with Previously Approved Travelers 49 Technical Specifications Task Force TSTF A Joint Owners Group Activity RITSTF Initiative 1 Travelers (TSTFs 423A, 422A, 431)

  • RITSTF Initiative 1 Traveler on hold since March 2008.

- NRC agreed to send letter to TSTF and BWROG on from TSTF423 at 9/30/2008 meeting.

- Status: Letter to TSTF received 5/5/09. Letter to BWROG pending. ETA?

  • RG 1.177, Tier 2 requirements not required to be in TS discussed at 9/11/2008 TSTF/NRC meeting.

- NRC agreed to send letter to TSTF responding to the TSTF white paper documenting that Tier 2 requirements are not required to be in TS TSTF423 at 9/30/2008 meeting.

- Status: Letter from NRC pending. ETA?

  • Applicability of LCO 3.0.4.a to Modified End States discussed at 9/11/2008 TSTF/NRC meeting.

- Followup meetings on 9/30/2008, 1/8/2009, and 1/30/2009.

- NRC agreed to send a letter to the TSTF requesting Traveler revision on 1/30/2009.

- Status: Letter from NRC pending. ETA?

50 25

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF490A, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec

  • Approved by NRC on 3/15/07.
  • Approved pp for ANO Unit 2, Millstone Units 2 and 3, Point Beach
  • Approved prior to CLIIP for Callaway, Wolf Creek, Comanche Peak, and Diablo Canyon
  • At 1/30/2009 TSTF/NRC meeting, NRC stated that the model application and/or SE referred to a September 27, 2006 document that is not public.

The accession number is ML062700612. NRC was going to make document public or reissue FRN.

- Status of action?

  • We understand that the current issue is whether multiple dose conversion factors may be referenced in the Dose Equivalent I131 Definition.
  • Are there any other issues?

(continued) 51 Technical Specifications Task Force TSTF A Joint Owners Group Activity From TSTF-490 Expanded on next slide 52 26

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity 53 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF439A, Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO

  • TSTF439 was approved by the NRC in a letter dated 1/11/2006.
  • TSTF439 eliminated "second Completion p Times" from several specifications to facilitate riskinformed Completion Times.

- These second Completion Times were added to the ISTS due to concerns over abuse of multiple Condition entry. These concerns are now addressed by availability targets in the Maintenance Rule.

  • TSTF439 was the result of over 4 years of discussion with the NRC.

- The NRC's approval of TSTF439 stated, "The NRC Staff concludes that multiple continuous entries into Conditions, without meeting the LCO, is acceptable because these practices will be controlled by licensee licenseess configuration risk management programs, which were implemented to meet the requirements of the maintenance rule to assess and manage risk, and controlled by the Use and Application convention discussed in Section 1.3 of the Technical Specifications. The TS controls, coupled with the licensees configuration risk management programs, provide adequate assurance against inappropriate use of combinations of Conditions that result in a single contiguous occurrence of failing to meet the LCO."

(continued) 54 27

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF439A, Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO

  • TSTF439 has been approved for several plants, including Crystal River, Monticello, Millstone 2, Fermi, Callaway, and Comanche Peak
  • Only Comanche Peak was required to make an additional commitment in order to adopt TSTF439. Ft. Calhoun was requested to make a similar commitment.
  • "There shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO for TS 3.7.5*Auxiliary Feedwater (AFW) System, TS 3.8.1, A.C. Sources Operating, and TS 3.8.9, Distribution Systems Operating. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended. The administrative controls t l will ill ensure th thatt C Completion l ti TiTime iis NOT extended t d db beyondd th the additive dditi C Completion l ti Times of the two (2) Required Actions for restoration of OPERABILITY unless a risk evaluation is performed. If Unit Operation within an LCO will exceed the maximum Completion Time, then either the shutdown Condition within the LCO should be entered OR a risk evaluation shall be performed and the risk impact managed under the Configuration Risk Management Program (CRMP)."
  • Would like to discuss why the requirements for adopting TSTF439 are changing so that we can advise licensees on the expectations. 55 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF400, "Clarify SR on Bypass of DG Automatic Trips"
  • TSTF400 was originally a Basesonly Traveler that clarified that SR 3.8.1.13 only verifies that non noncritical critical trips are bypassed (and not that the critical trips are not bypassed).

Justification based on consistency with Reg Guide 1.9.

  • NRC approved Revision 0 and incorporated it into Rev. 3 of the ISTS.
  • NRC subsequently requested that the SR be revised so that it is clear.

clear TSTF agreed and TSTF400, TSTF400 Rev. Rev 1,1 was approved on 11/13/2004 and incorporated it into ISTS Revision 3.1.

(continued) 56 28

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity After TSTF-400 (continued) 57 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF400, "Clarify SR on Bypass of DG Automatic Trips"

  • In several recent amendments, the NRC has requested licensees to commit that they will continue to test critical and noncritical EDG trips periodically per the maintenance program.
  • Catawba & McGuire included a Bases statement. Grand Gulf made a commitment. Other plants have received similar RAIs.

58 29

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF475, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action

  • At the 9/11/2008 TSTF/NRC meeting, NRC stated t t d that th t would ld revise i and d notice ti TSTF TSTF475 475 to correct the NSHC.
  • Does the NRC still plan to change the Notice?

59 Technical Specifications Task Force TSTF A Joint Owners Group Activity Technical Issues 60 30

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity RG 1.174 Tier 2 Requirements

  • Discussed under Initiative 1 Travelers.

61 Technical Specifications Task Force TSTF A Joint Owners Group Activity Development of ISTS Rev. 4 62 31

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity ISTS Revision 4 Development

  • ISTS Rev. 0 September 1992
  • ISTS Rev. 1 April 1995
  • ISTS Rev. 2 April 2001
  • ISTS Rev. 2.1 June 2001
  • ISTS Retyped by TSTF into MS Word format
  • ISTS Rev. 3 April 2004
  • ISTS Rev. 3.1 December 2005 (continued) 63 Technical Specifications Task Force TSTF A Joint Owners Group Activity ISTS Revision 4 Development
  • Development of ISTS Rev. 0 2.1 (19922001):

- NRC and TSTF agreed on Travelers to be incorporated.

- NRC typed revised NUREGs.

- Repeat the following

  • NRC sends draft NUREGS to TSTF for review
  • Industry reviewed the Traveler incorporation and provided comments
  • NRC incorporated comments and provided revised drafts

- NRC issues revised NUREGs (continued) 64 32

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity ISTS Revision 4 Development

  • The industry performed four rounds of review and comment on the draft Rev. 2. When issued, over 500 errors were discovered.
  • As a result, prior to creation of ISTS Rev. 3, the TSTF and NRC agreed in 2002:

- The TSTF would retype the ISTS NUREGs into MS Word format at our cost.

- The TSTF would create future revisions of the ISTS which the NRC would proof and review (track changes and clean copies)

- The TSTF would provide Acrobat copies of the NUREGs to the NRC for publication.

  • This process was followed successfully for Rev. 3.0 and 3.1 of the ISTS and both Owners Groups had budgeted funds to develop Rev. 4 using this process in 2009. 65 (continued)

Technical Specifications Task Force TSTF A Joint Owners Group Activity ISTS Revision 4 Development

  • The TSTF wants to work with the NRC to develop, review and publish Rev review, Rev. 4
  • We would like review with the NRC the "lessons learned" from earlier revisions
  • We want to ensure that Rev. 4 changes are consistent with the Writer's Guide

R 4

  • TSTF has Word files for all approved Travelers (continued) 66 33

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity Risk Informed ISTS NUREG

  • NRC suggestion for Risk Informed (e.g.,

I iti ti 4b and Initiative d 5b) ISTS NUREG NUREGs and d nonrisk ik informed NUREGs

  • TSTF does not believe this is beneficial.
  • Both TSTF425 (5b) and TSTF505 (4b) are written showing both existing and revised requirements in brackets (TS & Bases)
  • Survey indicates that most plants will adopt TSTF425 and TSTF505 in the next few years 67 Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-425 Example TSTF-505 Example 68 34

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity ISTS Revision 4 Development

  • Correction of inconsistent Note locations in th ISTS the
  • Issue: When is a Note to the right of the designator and when above the designator?

- See next slide

  • Recommend TSTF creates a T T Traveler which the NRC agrees to incorporate in Rev. 4.

(continued) 69 Technical Specifications Task Force TSTF A Joint Owners Group Activity 35

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity Future Planning 71 Technical Specifications Task Force TSTF A Joint Owners Group Activity FollowUp Actions From Workshop

- Ultrasonic flow meter T Traveler - B&W plants will not pursue generically.

- TSTF conveyed to both Owners Groups the NRC expectation that the LCO Bases clearly explain system Operability and use terminology consistent with the Specification.

- PWROG and BWROG agreed to support a Traveler to clarify LCO 3.0.4.a, LCO 3.0.5, and Operational Convenience.

- PWROG and BWROG agreed to review Required Actions to determine if the NRC position on Required Action completion has unintended consequences.

  • NRC Actions

- Withdrawal of Palisades TIA to prevent future confusion. Status?

72 36

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity Travelers Under Development

  • TSTF505, "Provide RiskInformed Extended C

Completion l ti TiTimes RITSTF Initiative I iti ti 4b"

- Reviewed by Owners Groups, resolving comments

- Submit this summer

  • BWROG Initiative 4a & 6 Topical Reports and Travelers

- Waiting for resolution of CE Initiative 6 issues

- Submit this summer (continued) 73 Technical Specifications Task Force TSTF A Joint Owners Group Activity Travelers Under Development

  • Traveler to revise ventilation system S

Surveillance ill Requirements R i t to t operate t with ith heaters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month

- Based on latest version of Reg Guide 1.54

- Submit this summer 74 37

6/4/2009 Technical Specifications Task Force TSTF A Joint Owners Group Activity Travelers Under Development

  • TSTF517, "Allowance for NonTS Cooling /

V til ti SSystems Ventilation t D Degradation d ti on SSupportt System Operability"

- Very similar to TSTF427, which pertains to barriers that support TS systems

- Submit this summer 75 Technical Specifications Task Force TSTF A Joint Owners Group Activity Next Meeting

  • TSTF November 4 (Wednesday day after election l ti d day))
  • TSTF/NRC November 5 (Thursday) 76 38