TSTF-08-17, Request for Fee Exemption for TSTF-511, Revision 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26.

Request for Fee Exemption for TSTF-511, Revision 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26.

ML082670291
Person / Time
Site:	Technical Specifications Task Force
Issue date:	09/22/2008
From:	David Bice, Gambrell R, Joseph Messina, Yates B B & W Owners Group, BWR Owners Group, Combustion Engineering Owners Group, Joint Owners' Group, PWR Owners Group, Technical Specifications Task Force, Westinghouse Owners Group
To:	Office of Nuclear Reactor Regulation, NRC/OCFO
References
TSTF-08-17
Download: ML082670291 (2)

Text

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY September 22, 2008 TSTF-08-17 PROJ0753 Chief Financial Officer U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Request for Fee Exemption for TSTF-511, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26"

REFERENCE:

Letter to the U.S. Nuclear Regulatory Commission from the TSTF, "Transmittal of TSTF-511, Revision 0, 'Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26'," dated September 17, 2008.

Dear Sir or Madam:

In the referenced letter, the TSTF submitted TSTF-511, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26," for NRC review.

The TSTF requests that a fee waiver be granted for the review of TSTF-511. The Technical Specification changes proposed in TSTF-511 are necessary to comply with the new 10 CFR Part 26, Subpart I, approved by the NRC on March 31, 2008. The new Part 26 requirements supersede the current Technical Specification requirements, rendering the Technical Specification requirements unnecessary and potentially conflicting with the new regulation.

Therefore, compliance with the new Part 26, Subpart I, requires that the Technical Specifications be revised.

We request that the NRC's review of the Traveler be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. This Traveler meets the exemption requirement in 10 CFR 170.11(a)(1)(iii), in that it is a means of exchanging information between industry organizations and the NRC for the specific purpose of supporting the NRC's generic regulatory improvements or efforts. In this case, the generic regulatory improvement effort is the NRCs revision to 10 CFR Part 26, Subpart I, on managing worker fatigue. The proposed Traveler is a mechanism for the NRC and industry organizations (the Technical Specification Task Force and the sponsoring Owners Groups) to exchange information with regard to the appropriate Technical Specification changes needed to reflect the NRC's generic regulatory improvement issued as 10 CFR Part 26, Subpart I.

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TSTF 08-17 September 22, 2008 Page 2 Should you have any questions, please do not hesitate to contact us.

Bert Yates (PWROG/W) John Messina (BWROG)

David Bice (PWROG/CE) Reene' Gambrell (PWROG/B&W) cc: Robert Elliott, Technical Specifications Branch, NRC Matthew Hamm, Technical Specifications Branch, NRC