ML042580010
| ML042580010 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/2004 |
| From: | Tjader T NRC/NRR/DIPM/IROB |
| To: | Bradley B Nuclear Energy Institute |
| Tjader T., NRC/IROB, 415-1187 | |
| Shared Package | |
| ML042580006 | List: |
| References | |
| Download: ML042580010 (8) | |
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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, 949 368-9431EXCEL/
TSTFDonald 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 29/09/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER1Technical SpecificationRequired ActionsPreferred End States Industry and NRCdeveloping implementationguidance for TSTF-422 and TSTF-423. NRC/Industry met 1/30/04 on TSTF 422 andTSTF 423. The NRC/RITSTF agreed toresolutions for all the NRC comments. A draft of the TSTF-422 implementation guidancedocument was provided to the NRC for commentin 6/04. NRC provided comments on 7/9/04 and arevised document has been developed to address these comments. The document will be submitted to NRC by 9/20/04. NRC will attempt to issue TSTF 422 Notice forComment and Availability in 2004. TSTF-423 was submitted to the NRC on 8/12/03. RITSTF provided draft responses to NRCcomments on TSTF 423 at the 1/30/04 meeting. A draft of the TSTF-423 implementation guidancedocument was provided to the NRC on 7/20/04.
The NRC had not provided any comments before the 9/9/04 meeting. The NRC wants more information in the BWROGTSTF 423 Implementation Guidance. Based on review of the CEOG TSTF 422Implementation Guidance, the NRC will providethe scope of additional information they want to BWROG.CEOG - TSTF-422 R0BWROG - TSTF-423 R0BWOG - TSTF-431 R0 WOG - TSTF-432 R0(Not created)
RITSTF INITIATIVE STATUSPage 2 of 29/09/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER1Technical SpecificationRequired ActionsPreferred End States Industry and NRCdeveloping implementation guidance for TSTF-422 and TSTF-423. BWOG Topical Report was submitted to NRC on1/19/04. The NRC provided an RAI on 6/29/04.BWOG informed the NRC they could not respond to the RAI until early 2005, and the NRC has put review of the Topical Report on hold. TSTF-431 has been distributed to the BWOG andthe RITSTF for review.CEOG - TSTF-422 R0BWROG - TSTF-423 R0BWOG - TSTF-431 R0 WOG - TSTF-432 R0(Not created)
RITSTF INITIATIVE STATUSPage 3 of 29/09/2004INITIATIVETITLEINITIATIVE 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 R1 (ALL OG)TSTF-446 R0 (WOG)TSTF-454 R0 (BWROG)
RITSTF INITIATIVE STATUSPage 4 of 29/09/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER4bRisk Informed AOTsWith ConfigurationRisk Management Program or Maintenance Rule BackstopHope Creek, Fort Calhoun,South Texas Project, and PrairieIsland have volunteered to develop pilot submittals.Fort Calhoun and South TexasProject have submitted theirpilots. RITSTF will develop a White Paper to address theinterface of the a.4 process to the Initiative 4b and Initiative 6 process to show the overlap and transition for ITS and non ITS plants and provide to NRC in October 2004. NRC provided 3 separate RAIs in 8/04 to NEI. The RITSTF has created an Initiative 4b Subgroupto coordinate responses to the NRC RAIs. Current schedule is to provide responses to NRCand meet in 12/04.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 12/04.None assigned5bRelocate SurveillanceTest Intervals toLicensee Control RITSTF/BWROG/PilotPlant will be applying themethodology andinterfacing with the NRC on the issues in 2004. NRC attended several Limerick IDP meetings toobserve process. The Limerick lead plant license amendment wassubmitted on June 11, 2004. TSTF-425 was submitted to the NRC on 8/31/04. NEI is preparing the methodology document forsubmittal to the NRC in 09/04.TSTF-425 R0 RITSTF INITIATIVE STATUSPage 5 of 29/09/2004INITIATIVETITLEINITIATIVE 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 issued SafetyEvaluation for Topical Report on 7/9/04. TSTF-426 R0 wassubmitted to the NRC on8/30/2004. CEOG submitted revised version of TopicalReport to address NRC RAIs in 10/03. NRC issued Safety Evaluation for Topical Reporton 7/9/04. TSTF-426 R0 was submitted to the NRC on8/30/04. RITSTF submit draft Implementation Guidance in11/04.TSTF-426 R06cProvide Specific Timesin the LCO For Those Conditions That Require Entry Into LCO 3.0.3 Immediately NRC issued SafetyEvaluation for Topical Report on 7/9/04. TSTF-426 R0 wassubmitted to the NRC on8/30/2004. CEOG submitted revised version of TopicalReport to address NRC RAIs in 10/03. NRC issued Safety Evaluation for Topical Reporton 7/9/04. TSTF-426 R0 was submitted to the NRC on8/30/04. RITSTF submit draft Implementation Guidance in11/04.TSTF-426 R0 RITSTF INITIATIVE STATUSPage 6 of 29/09/2004INITIATIVETITLEINITIATIVE STATUSNEXT ACTIONS/SCHEDULE/RESPONSIBILITYTSTF NUMBER7aImpact of NonTechnical SpecificationDesign Features on Operability Requirements - Barriers TSTF-372, Rev. 4submitted on 4/23/04. TSTF-427 submitted on3/4/03. NRC provided commentson TSTF-427 on 6/26/03. Draft Revision 4 of TSTF-372 created on 2/24/03.NRC reviewed and agreed it addressed theircomments. TSTF-372, Rev. 4 submitted to NRC on 4/23/04. On 5/28/04, the NRC requested additionalinformation to support review of TSTF-372. TheTSTF/RITSTF responded on 6/7/04. NRC requested additional information in 7/04 andIndustry/NEI responded with responses 9/7/04. NRC plans FRN for Comment for TSTF 372 by10/04. NRC provided feedback on RITSTF responses onTSTF 427 in February 2004. TSTF/RITSTF will delete the additions to thedefinition of OPERABILITY for TSTF 427 to address NRC concerns. TSTF-427 implementation guidance beingdeveloped and will be provided to the NRC by09/17/04. TSTF/RITSTF will provide a revision to TSTF-427 after completion of the implementation guidance document.TSTF-372 R4TSTF-427 R0 RITSTF INITIATIVE STATUSPage 7 of 29/09/2004INITIATIVETITLEINITIATIVE 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 10/04. RITSTF/TSTF reviewed and has commented onthe revised Operability guidance that will supersede the guidance distributed with GL 91-18. RITSTF/TSTF will develop a TSTF and submit toNRC by 12/04.None assigned8aRemove or RelocateSystems LCOs That Do Not Meet the 4Criterion of 10 CFR50.36 From Technical Specifications A White Paper on theapplication of the 10 CFR 50.36 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 for relocation. RITSTF working on the schedule -
current plans are fourth quarter 2004.None assigned RITSTF INITIATIVE STATUSPage 8 of 29/09/2004INITIATIVETITLEINITIATIVE 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