ML040540678

02/11/2004, Risk Informed Technical Specification Task Force (RITSTF) Risk Management Technical Specification Initiative Status

ML040540678
Person / Time
Issue date:	02/23/2004
From:	Tjader T NRC/NRR/DIPM/IROB
To:	Bradley B Nuclear Energy Institute
Tjader T., NRC/IROB, 415-1187
Shared Package
ML040540662	List: ML040540668 ML040540678 ML040540685
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Download: ML040540678 (7)

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RISK INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)RISK MANAGEMENT TECHNICAL SPECIFICATION INITIATIVE STATUSNEI RITSTFNEIBiff Bradley, 202 739-8083WOGJack Stringfellow, Southern Nuclear, 205 992-7037CEOGAlan Hackerott, OPPD, 402 533-7276Tony Pietrangelo, 202 739-8081Jim Andrachek, Westinghouse, 412 374-5018Gary Chung, SCE, 949 368-9431EXCELDon Hoffman, 301 984-4400 Jerry Andre, Westinghouse, 412 374-4723Ray Schneider, CE, 860 731-6461 EPRIFrank Rahn, 650 855-2037 BWOGPaul Infanger, Progress Energy, 352-563-4796BWROGRick Hill, GE, 408 925-5388John Gaertner, 704 547-6169 R. Schomaker, Framatome, 434 832-2917Dusty Rhoads, Energy Northwest, 509 377-4298Mike Kitlan, Duke, 980 373-8348Don McCamy, TVA 256 729-4595Page 1 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER1Technical SpecificationRequired ActionsPreferred End States NRC provided commentson TSTF-422 on 6/23/03.TSTF and RITSTF provided responses on 11/10/03. TSTF-423 submitted toNRC on 8/12/03. TSTF-422, Rev. 1 was submitted to the NRC on1/24/03. The NRC provided comments on TSTF-422 on6/23/03. The TSTF and RITSTF provided responses on 11/10/03. Following NRC acceptance of comments, the final TSTF-422 willbe submitted. The BWROG SE was issued 9/27/02 and theBWROG Topical A version was issued in 2/03. TSTF-423 was submitted to the NRC on 8/12/03. TSTF reviewed and provided comments on theBWOG Topical Report. BWOG Topical Report was submitted to NRCweek of 1/23/04. RITSTF provided draft responses to NRCcomments on TSTF 423 at the 1/30/04 meeting. NRC/Industry met 1/30/04 on TSTF 422 andTSTF 423. The NRC/RITSTF agreed to resolutions for all theNRC comments. TSTF will revise the TSTFs 422 and 423accordingly and RITSTF/TSTF will provide a draft of the Initiative 1 Implementation Guidance to the NRC in March 2004.CEOG - TSTF-422 R0BWROG - TSTF-423 R0BWOG - TSTF-431 R0(Not created)WOG - TSTF-432 R0(Not created)

RITSTF INITIATIVE STATUSPage 2 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER2Missed SurveillancesSR 3.0.3 TSTF-358, R6, has beenapproved and published forCLIIP adoption. Initiative Complete.TSTF-358 R63Increase Flexibility inMode Restraints LCO 3.0.4 TSTF-359, R9, has beenapproved and published for CLIIP adoption. The final ImplementationGuidance, NEI-03-10, wasissued on September 5, 2003. Initiative Complete.TSTF-359 R94aIndividual RiskInformed Allowed Outage Times (AOTs) Owners Groups (OGs) arepursuing generic Risk Informed AOT extensionsthrough OG-specificTopicals and license amendments. Ongoing.TSTF-373 R2 (CEOG)TSTF-409 R1 (CEOG)TSTF-417 R0 (WOG)TSTF-430 R0 (BWOG)

TSTF-439 R1TSTF-446 R0 (WOG)TSTF-454 R0 (BWROG)

RITSTF INITIATIVE STATUSPage 3 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER4bRisk Informed AOTsWith ConfigurationRisk Management Program or Maintenance Rule BackstopTSTF-424 and the Draft RiskManagement Guide wereprovided to the NRC on 1/21/03. NRC provided acceptance review comments onTSTF-424 on 10/2/03. NRC to provide first roundof RAIs in the near future. RITSTF provided the Interim Report to NRC atthe 11/13/03 meeting. RITSTF provided the Matrix of the responses tothe NRC comments to NRC on 11/21/03. RITSTF/NRC met to discuss the responses anddocuments 12/16/03. STP met with NRC to discuss specifics of STPsubmittal 1/21/04. RITSTF/NRC met 1/29/04 to discuss the TSTF424 and associated risk guidance document. RITSTF provided draft responses to NRCcomments at the 1/29/04 meeting. RITSTF will develop a White Paper to address theinterface of the a.4 process to the Initiative 4b andInitiative 6 process to show the overlap and transition and provide to NRC in March 2004. NRC will provide comments on the RMGDIndustry response to NRC comments in March 2004.TSTF-424 R05aRelocate SurveillanceRequirements Not Related to Safety Deterministic portion ofInitiative 5 transferred to TSTF responsibility. TSTF reviewing candidate SRs to be relocated. TSTF will provide a TSTF to the NRC by 6/04.None assigned RITSTF INITIATIVE STATUSPage 4 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER5bRelocate SurveillanceTest Intervals toLicensee Control RITSTF/BWROG/PilotPlant will be applying themethodology and interfacing with the NRC on the issues in 2003. RITSTF to address NRCposition that SurveillanceTest Intervals must be in the Technical Specifications NRC provided a new concern regardingSurveillance Test Intervals at 5/15/03RITSTF/NRC meeting. NRC stated that OGC was concerned that test intervals (Frequencies) should remain in Technical Specifications under 10 CFR 50.36. It may be acceptable for the Technical Specifications to contain a methodologyrather than a fixed interval. RITSTF to address NRC position that SurveillanceTest Intervals must be in the Technical Specifications and NEI to provide a White Paperto NRC. BWROG has identified two pilot plants and willdevelop a draft Traveler based on the application of the methodology. BWROG will attach the Guidance Document to the TSTF. RITSTF provided a draft Technical GuidanceDocument to the NRC at the 11/13/03 meeting. NRC attended several Limerick IDP meetings toobserve process. The TSTF is working closely with Limerick toensure cohesiveness of the Limerick LAR and the TSTF. Three documents will be submitted in late 3/04 toearly 4/04:

1. Limerick Pilot as a License AmendmentRequest.2. The Methodology Document

3. TSTF 425.TSTF-425 R0(Not created)

RITSTF INITIATIVE STATUSPage 5 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER6aModify LCO 3.0.3Actions and Timing 1hour - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> On hold. On hold for resolution of Initiative 6b and 6c todetermine if Initiative 6a is required.None assigned6bProvide Conditions inthe LCOs for Those Levels of Degradation Where No Condition Currently Exists toPreclude Entry IntoLCO 3.0.3 NRC drafting SafetyEvaluation. CEOG provided revised version to address theRAIs to NRC in 7/03. NRC PSA Branch developed a draft SE and NRCwill finalize the SE based on the CE responses. CEOG to provide a list of ISTS changes andjustification to TSTF after NRC completes Safety Evaluation. TSTF reviewed CEOG Topical Report andrecommended changes to support creation of a Traveler. CEOG developed a revision to the Topical to address NRC comments and the TSTF comments. This revised topical was submitted to NRC10/3/03. The revised Topical is under NRC review andNRC plans to issue the draft SE 4/30/04. TSTF to be submitted after NRC issues SE onTopical.TSTF-426 R0(Not created)

RITSTF INITIATIVE STATUSPage 6 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER6cProvide Specific Timesin the LCO For ThoseConditions That Require Entry Into LCO 3.0.3 Immediately NRC drafting SafetyEvaluation. CEOG provided revised version to address theRAIs to NRC in 7/03. NRC PSA Branch developed a draft SE and NRCwill finalize the SE based on the CE responses. CEOG to provide a list of ISTS changes andjustification to TSTF after NRC completes SafetyEvaluation. TSTF reviewed CEOG Topical Report andrecommended changes to support creation of aTraveler. CEOG developed a revision to theTopical to address NRC comments and the TSTF comments. This revised topical was submitted to NRC10/3/03. The revised Topical is under NRC review andNRC plans to issue the draft SE 4/30/04. TSTF to be submitted after NRC issues SE onTopical.TSTF-426 R0(Not created)

RITSTF INITIATIVE STATUSPage 7 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER7aImpact of NonTechnical SpecificationDesign Features on Operability Requirements - Barriers NRC provided commentson TSTF-427 on 6/26. Revision 3 of TSTF-372submitted on 11/17/03. Draft Revision 4 of TSTF-372 created on 2/24/03.NRC reviewed and agreed it addressed theircomments. Draft being reviewed by TSTF, RITSTF, and Snubbers Users Group (SNUG). TSTF, Snubbers User Group (SNUG), and NRCmet to discuss TSTF-372 on June 16. SNUGgathered information from their members andworked with the TSTF to draft a revision that addresses the NRC and Industry concerns.

Submitted Revision 3 on 11/17/03. Draft Traveler for Initiative 7a (TSTF-427) draftedfor discussion with the RITSTF on 12/18/02 and NRC 12/19/02. TSTF-427 transmitted to NRC on 3/4/03. NRC provided comments on TSTF-427 on6/26/03. RITSTF provided response to NRC comments on 11/7/03. RITSTF/NRC discussed the RITSTF response atthe 11/13/03 meeting. NRC will provide feedback on RITSTF responseson TSTF 427 by February 2004. TSTF/RITSTF will delete the additions to thedefinition of OPERABILITY for TSTF 427 and372 to address NRC concerns. TSTF/RITSTF will provide bounding analysis inthe TSTF 372 for snubbers that affect both trains of a system. TSTF/RITSTF will provide revisions to TSTF 372and TSTF 427 in March 2004. NRC will review and respond on TSTF 372 inMarch 2004.TSTF-372 R3TSTF-427 R0 RITSTF INITIATIVE STATUSPage 8 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER7bImpact of Non TSDesign Features onOperability Requirements - All other SSCs not in Technical Specifications A White Paper on theprocess to address this scopeof SSCs is being developed. RITSTF will develop a White Paper to outline theprocess to address this scope of SSCs by 6/04. RITSTF/TSTF will work with the NRC on a riskinformed revision of GL 91-18 and integrate the Initiatives. An Operability/GL 91-18 Workshop was held on8/14/03 to discuss these issues. A draft revision of GL 91-18 will be available3/04 with another GL 91-18 Workshop currentlyscheduled for 4/09/04 RITSTF/TSTF will develop a TSTF and submit toNRC by 8/04.None assigned8aRemove or RelocateSystems LCOs That DoNot Meet the 4Criterion of 10 CFR 50.36 From Technical Specifications A White Paper on theapplication of the 10 CFR50.36 criteria is beingdeveloped. NEI 00-04 is being reviewed and will serve as thebasis for Criterion 4 application. RITSTF will develop a White Paper to outline theguidance and methodology based on NEI 00-04 for the application of the four criteria of 10 CFR 50.36 and a list of the systems identified forrelocation. RITSTF working on the schedule -current plans are third quarter 2004.None assigned RITSTF INITIATIVE STATUSPage 9 of 92/11/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER8bModify 50.36 Rule toPermit Removal orRelocation of Non Risk Significant Systems out of Technical Specifications Requires Rulemaking RITSTF looking at coordinating Initiative 8b withlonger term initiatives given the requirements forrulemaking. Approach favored by NEI and NRC is makingCriterion 4 a "two way door" (e.g., if it doesn't meet Criterion 4, Specification can be relocatedeven if it meets Criteria 1, 2, or 3).Not applicableBWOG - Active in Initiatives 1, 4 and 7CEOG - Active in Initiatives 1, 4, 5 and 6 BWROG - Active in Initiatives 1, 4, 5 and 8WOG - Active in Initiatives 1, 4, and 5