TSTF-13-10, Technical Specifications Task Force - Request for Fee Exemption for TSTF-545, TS Inservice Testing (IST) Program Removal

Technical Specifications Task Force - Request for Fee Exemption for TSTF-545, TS Inservice Testing (IST) Program Removal

ML13309B602
Person / Time
Site:	Technical Specifications Task Force
Issue date:	11/04/2013
From:	Croft W, Gustafson O, Loeffler R, Slough R BWR Owners Group, PWR Owners Group, Technical Specifications Task Force
To:	NRC/OCFO
Hudson, Sharon
References
TSTF-13-10
Download: ML13309B602 (2)

Text

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY November 4, 2013 TSTF-13-10 PROJ0753 Chief Financial Officer U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Request for Fee Exemption for TSTF-545, "TS Inservice Testing (IST)

Program Removal"

Dear Sir or Madam:

On August 23, 2012, the NRC issued Regulatory Issue Summary (RIS) 2012-10, "NRC Staff Position on Applying Surveillance Requirement 3.0.2 and 3.0.3 to Administrative Controls Program Tests." The RIS stated that the NRC staff had determined that restructuring Technical Specifications (TS) chapters during the development of the Improved Standard Technical Specifications (ISTS) resulted in unintended consequences when Section 3.0, "Surveillance Requirement Applicability," provisions were made applicable to Section 5.0 TS. The NRC staff concluded that SR 3.0.2 and SR 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS SR, despite explicit statements in the Section 5.5 TS that these provisions are applicable.

In order to provide time for licensees to address the NRC position, the NRC issued Enforcement Guidance Memorandum (EGM) 2012-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests," on February 24, 2012. The EGM provided enforcement discretion to licensees to apply SR 3.0.2 to Inservice Tests and guidance on addressing missed Inservice Tests, pending revision to the ASME OM Code and the TS.

The EGM stated that the generic resolution of this issue will include a proposed Technical Specifications Task Force (TSTF) Traveler for revising the ISTS. The TSTF Traveler will be made available using the NRC Consolidated Line Item Improvement Process (CLIIP) by NRC issuance of a Notice of Availability (NOA) for the model, to allow timely processing of license amendments by the NRC. TSTF-545, "TS Inservice Testing (IST) Program Removal," was developed in response to the RIS and the EGM to facilitate generic resolution of this issue regarding the IST Program.

At a TSTF and NRC public meeting held on May 2, 2013, the NRC staff confirmed plans to use a TSTF Traveler to resolve the issues discussed in RIS 2012-10 and in EGM 2012-001.

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation

TSTF 13-10 November 4, 2013 Page 2 The TSTF requests that the NRC's review of TSTF-545 be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. The 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 development of a consistent industry approach to address the concerns expressed in RIS 2012-10 and EGM 2012-001. The role of the TSTF Traveler in this NRC generic regulatory effort is explicitly acknowledged in EGM 2012-001.

Should you have any questions, please do not hesitate to contact us.

Robert Slough (PWROG/W) Richard A. Loeffler (BWROG)

Otto W. Gustafson (PWROG/CE) Wendy E. Croft (PWROG/B&W) cc: Michelle Honcharik, Licensing Processes Branch, NRC Robert Elliott, Technical Specifications Branch, NRC