ML051450421

From kanterella
Revision as of 21:32, 20 September 2018 by StriderTol (talk | contribs) (Created page by program invented by StriderTol)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
04/21/2005 Summary of Meeting with the Risk-Informed Technical Specification Task Force
ML051450421
Person / Time
Issue date: 05/13/2005
From: Tjader T R
NRC/NRR/DIPM/IROB
To: Bradley B
Nuclear Energy Institute
Tjader T., NRC/IROB, 415-1187
References
Download: ML051450421 (20)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION 0 tWASHINGTON, D.C. 20555-0001 0May 16, 2005 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 1 Street, NW Washington, DC 20006-3708

SUBJECT:

SUMMARY

OF MEETING ON APRIL 21,2005, WITH THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE

Dear Mr. Bradley:

The purpose of this letter is to transmit the summary of a meeting with the Risk-Informed Technical Specification Task Force. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on April 21, 2005. Significant progress is being made on the Risk Management Technical Specifications Initiatives.

The meeting was expanded to include a discussion of the Risk Management Technical Specifications Initiative 4b, Risk-Informed Completion Times, Risk Management Guidance Document.Sincerely, T. R. Tjader, Senior Reactor Engineer Technical Specifications.Section Reactor Operations Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation

Enclosures:

1. Meeting Summary 2. Attendance List 3. Agenda 4. RITSTF Initiative Status 5. RMTS Initiative 4b Risk Management Guidance Document Discussion Topics 6. White Paper, Interface of RITSTF Initiative 4b and Initiative 6b/c cc w/encl: See next page flay 16, 2005 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708

SUBJECT:

SUMMARY

OF MEETING ON APRIL 21,2005, WITH THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE

Dear Mr. Bradley:

The purpose of this letter is to transmit the summary of a meeting with the Risk-Informed Technical Specification Task Force. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on April 21, 2005. Significant progress is being made on the Risk Management Technical Specifications Initiatives.

The meeting was expanded to include a discussion of the Risk Management Technical Specifications (RMTS)Initiative 4b, Risk-Informed Completion Times, Risk Management Guidance Document.Sincerely,/RA/T. R. Tjader, Senior Reactor Engineer Technical Specifications Section Reactor Operations Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation

Enclosures:

1. Meeting Summary 2. Attendance List 3. Agenda 4. RITSTF Initiative Status 5. RMTS Initiative 4b Risk Management Guidance Document Discussion Topics 6. White Paper, Interface of RITSTF Initiative 4b and Initiative 6b/c cc w/encl: See next page DISTRIBUTION:

See next page ADAMS ACCESSION NUMBER: DOCUMENT NAME: G:\DIPM\TSS\Tjader\RITSTF-MTGsum-4-21-05.wpd OFFICE TSS:IROB-A:DIPM lSC:TSS:IROB-A:DIPM ll NAME TRTjader 7Tq? THBoyce KM I DATE 05/G112005 05/ te/2005 e A l OFFICIAL RECORD COPY Mr. Biff Bradley cc via e-mail: Mr. Tony Pietrangelo Nuclear Energy Institute Mr. Biff Bradley Nuclear Energy Institute Mr. Mike Schoppman Nuclear Energy Institute Mr. Alan Hackerott, Chairman Omaha Public Power District Mr. Jim Kenny Pennsylvania Power & Light Company Mr. James Andrachek Westinghouse Electric Company Mr. Jack Stringfellow Southern Nuclear Operating Company Mr. Donald McCamy Browns Ferry Nuclear Plant Mr. Ray Schneider Westinghouse Electric Company Mr. Frank Rahn EPRI Mr. Wayne Harrison STP Mr. Drew Richards STP Mr. Gabe Salamon PSEG Nuclear Mr. Gene Kelly Exelon Mr. Glenn Stewart Exelon Mr. Phil Tarpinian Exelon Ms. Nancy Chapman SERCH/Bechtel Mr. Rick Hill General Electric Nuclear Energy Mr. Michael S. Kitlan, Jr.Duke Energy Corporation Mr. Noel Clarkson Duke Energy Corporation Mr. Donald Hoffman EXCEL Services Corporation Mr. Ted Book Framatech-ANP Mr. R. J. Schomaker Framatech-ANP Mr. J. E. Rhoads Energy Northwest Ms. Deann Raleigh Scientech Mr. Ken Canavan DS&S Mr. Sam Chien SCE Mr. Gary Chung SCE-SONGS Mr. Courtney Smyth PSEG Nuclear LLC Mr. Jerry Andre Westinghouse Electric Company Mr. David Helher Exelon Mr. James Liming ABSG Mr. Stanley Levinson Framatone ANP Mr. John Gaertner EPRI DISTRIBUTION:

ADAMS PUBLIC TSS R/F TSS Staff BABoger/MJCase (RidsNrrDipm)

SCBIack (RidsNrrDssa)

MDTschiltz (RidsNrrSpsb)

LTMarsh/JELyons (RidsNrrDlpm)

JNHannon (RidsNrrDssaSplb)

TRQuay (RidsNrrDipmlehb)

OGC (RidsOgcRp)

ACRS/ACNW (RidsAcrsAcnwMailCenter)

NSaltos (NTS)MLWohI (MLW1)GSShukla (GSS)SPWall (SPW)WDReckley (WDR)FMReinhart (FMR)DGHarrison (DGH)CKDoutt (CKD)]DFThatcher (DFT)SDAlexander (SDA)PFPrescott (PFP)KCoyne (KXC)MDrouin (MXD)MCThadani (MCT)GWMorris (GWM2)YGHsii (YGH)DHShum (DHS)RKMathew (RKM)GWParry (GWP)ABWang (ABW)BMPham (BMP)AJHowe (AJHI)TWAlexion (TWA)MAStutzkie (MAS7)

SUMMARY

OF THE APRIL 21, 2005, NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE The NRC staff met with the NEI Risk-informed Technical Specification Task Force (RITSTF) on April 21, 2005, from 9:00 a.m. to 4:30 p.m. The meeting attendees are listed in Enclosure 2.The agenda (Enclosure

3) consisted of discussions of five of the active RITSTF initiatives, and Initiative 4a generic completion time extension submittals.

The RITSTF provided a summary of the status of the initiatives (Enclosure 4). Following is a brief description of the status of the initiatives in the order in which they were discussed.

Initiative 1, TS Actions End States Modifications:

The CE TSTF-422 will be published in the Federal Register requesting public comment in May 2005 (70 FR 23238, May 4, 2005), as part of the Consolidated Line Item Improvement Process (CLIIP). NEI will provide a final version of the implementation guidance for BWR TSTF-423, and its model SE will be published in the Federal Register, requesting public comment in about June 2005, as part of CLIIP. The staff has commenced review of the B&W Topical Report RAI Responses.

The WOG will submit its Topical Report in July 2005.Initiative 5, Relocation of non-safety SRs (5a) and relocation of all SR frequency requirements (5b) out of TS: Exelon submitted Limerick's proposed pilot plant license amendment request on June 25, 2004. The industry submitted an Initiative 5b methodology document in February 2005. The staff provided RAls on Limerick's proposed pilot plant license amendment and the Initiative 5b methodology.

In early June 2005 the staff and industry will meet to discuss the RAls.Initiative 8 a and 8b, Remove/Relocate non-safety and non-risk significant systems from TS that do not meet 4 criteria of 10 CFR 50.36: Initiative 8a would review tech specs to remove systems that were included solely because they were judged to be risk significant at one time and have now been shown by analysis not to be. The RITSTF will develop a white paper on Initiative 8a, outlining the guidance and methodology for implementation.

Initiative 8b would make the scope of technical specifications depend only on risk significance.

The RITSTF will interface with the NRC in the development of guidance and a methodology, based on NEI 00-04 (proposed NEI Option 2 implementing guidance), for the application of 10 CFR 50.36 criteria.

The RITSTF will develop and submit a white paper on Initiative 8b guidance and methodology for implementation.

Initiative 6, Modification of LCO 3.0.3 Actions and Completion Times: The staff approved and issued the SER on the CE Topical Report on July 9, 2004. Industry submitted a proposed CE TSTF-426 on August 30, 2004. The staff provided RAls for CE TSTF-426 on November 13, 2004. Industry will provide RAI responses and develop implementation guidance in May 2005.Initiative 7, Non-TS support system impact on TS operability determinations:

The staff will resolve issues related to the public comments received in response to the Federal Register Notice (69 FR 68412, November 24, 2004) and make TSTF-372, Inoperable Snubbers, available via CLIIP in May 2005 (70 FR 23252, May 4, 2005). The industry provided draft implementation guidance for TSTF-427, Inoperable Barriers, on September 20, 2004. The staff Enclosure 1 provided RAls for TSTF-427 on November 13, 2004. Industry responded to the staff's RAls on the proposed TSTF-427 implementation guidance on March 23, 2005. Staff and industry will meet in the near future to resolve RAI issues, with a goal of publishing a CLIIP model SE for public comment by August 2005.Initiative 4a, CT/AOT Extensions:

BWR TSTF-454 PCIV CT Extension draft SE is to be issued for public comment in May 2005 via CLIIP. WOG TSTF-446 CIV CT Extension draft SE is to be issued for public comment in June 2005 via CLIIP. The WOG will request a meeting to discuss future RG 1.177 submittals.

Initiative 4b, Risk Informed CTs/AOTs:

The industry and staff met in March 2005 to begin defining RMTS Initiative 4b requirements with respect to PRA and CRMP scope and capability.

This RITSTF meeting included a continuation of that earlier meeting, with discussions focusing on 14b processes (Enclosure 5). NEI provided a point paper on the nexus between 14b and Initiative 6, on LCO 3.0.3 entry times, and its relationship on how 14b might treat a TS system loss-of-function (Enclosure 6). In general, it is perceived that a voluntary TS system loss-of-function will not be permitted, and that time to restore an emergent TS system loss-of-function will be determined on a system-by-system basis. Also discussed was the interrelationship between TS Operability and PRA functionality.

It is recognized that the overwhelming majority of time the two will be identical, however, there will be instances where the two will diverge.The Risk Management Guidance (RMG) document must clearly address constraints and how the situation will be handled when the two are not the same. The industry and staff will meet again to continue defining RMTS Initiative 4b requirements with respect to PRA and CRMP scope and capability, and overall process. The industry will provide an updated RMTS RMG document, CE topical report and TSTF-424, in May 2005. The staff will provide RAls on the STP pilot LAR in May 2005. The staff will be developing a TI for providing inspection guidance, to be available this summer for comment. The ACRS has requested a meeting, scheduled for June 15, 2005, to discuss the quality and use of PRA and Risk Monitors in the Initiative 4b application.

Industry and the NRC staff will provide ACRS with a joint presentation on PRA and CRMP tools.The next NRC TSS/NEI RITSTF meeting is scheduled for August 17, 2005, at the NRC Headquarters.

NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE ATTENDANCE LIST APRIL 21, 2005 NAME BIFF BRADLEY TONY PIETRANGELO DON HOFFMAN JOHN GAERTNER JIM ANDRACHEK STANLEY LEVINSON WAYNE HARRISON DREW RICHARDS GARY CHUNG MARK RIEMER MIKE KITLAN JIM LIMING MICHAEL ADELIZZI DEANN RALEIGH TOM BOYCE BOB TJADER NANCY SALGADO MARK REINHART NICK SALTOS ANDREW HOWE AFFILIATION NUCLEAR ENERGY INSTITUTE NUCLEAR ENERGY INSTITUTE RITSTF/EXCEL SERVICES EPRI WESTINGHOUSE/WOG AREVA STP NOC STP NOC SCE FENOC DUKE ENERGY ABS CONSULTING PPL SUSQUEHANNA SCIENTECH NRC/NRRIDIPM/IROB/TSS NRC/NRR/DIPM/IROBITSS NRC/NRR/DIPM/IROBrTSS NRC/NRR/DSSA/SPSB NRC/NRR/DSSA/SPSB NRC/NRR/DSSANSPSB Enclosure 2

AGENDA TSS/NEI RITSTF MEETING APRIL 21, 2005 9:00 A.M. -4:30 P.M.0-12 B4 o Status of Initiatives o Initiative 1, End States CEOG TSTF-422 Status BWROG TSTF-423 Status B&W Topical, BAW-2441 o Initiative 5b, SR Frequency Evaluation Methodology/SR Frequency TS Program Limerick Pilot Status SR Frequency TS Program/Methodology o Initiative 8, Remove/Relocate non-safety

& non-risk significant systems from TS o Public Questions and Discussion o Initiative 6, LCO 3.0.3 Actions and Completion Times CEOG TSTF-426 Status o Initiative 7, Non-TS Support System Inoperability Impact on TS System & TSTF-372 TSTF-372, Rev 4, CLIIP Status TSTF-427 Status o Public Questions and Discussion o Initiative 4a, Generic RG 1.177 Completion Time Extensions o Initiative 4b, Risk-Informed Completion Times STP Pilot FCS Pilot CE Pilot, TSTF-424 Hope Creek Pilot Prairie Island Pilot o Public Questions and Discussion o Initiative 4b, Risk-informed Completion Times RMTS Risk Management Guidance Document ACRS Sub-Committees Meeting on PRA/CRM Monitors/Tools; June 15, 2005 o Public Questions and Discussion o Schedule Next Meeting Enclosure 3

RISK INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)RISK MANAGEMENT TECHNICAL SPECIFICATION INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

TSTF NUMBER____ ___ ____ __ ___ ____ ___ ___ RESPONSIBILITY Technical Specification NRC plans to issue CLIIP NRC/Industry met 1/30/04 on TSTF-422 and TSTF- TSTF-422 RO Required Actions Notice for Comment for TSTF- 423. The NRC/RITSTF agreed to resolutions for all (CEOG)Prcferred End States 422 in April and TSTF-423 in the NRC comments.May 2005..A draft of the TSTF-422 implementation guidance TSTF-423 RO document was provided to the NRC for comment in (BWROG)6/04. NRC provided comments on 7/9/04 and a revised document was submitted to the NRC on TSTF-43 1 RO 9/21/04. (BWOG)The NRC provided comments on the TSTF-422 implementation guidance on 10/13/04.

The final TSTF-432 RO TSTF-422 implementation guidance was submitted to (WOG the NRC in 12/04. v c (NVot created)NRC plans to issue TSTF-422 Notice for Comment in May 2005.NRC plans to issue TSTF-422 for Notice for Availability in August 2005.TSTF-423 was submitted to the NRC on 8/12/03.RITSTF provided draft responses to NRC comments on TSTF-423 at the 1/30/04 meeting.The NRC provided comments on TSTF-423 and the implementation guidance on 10/13/04.

The RITSTF provided responses and revised implementation guidance in 12/04.NRC plans to issue TSTF-423 Notice for Comment in June 2005. -NEI Biff Bradley 202 739-8083 Tony Pictrangelo 202 739-8081 TSTF Donald Hoffman, EXCEL 301 984-4400 EPRI Frank Rahn 650 855-2037 John Gaertner 704 547-6169 LNLI KITMIi WOG Jack Stringfcllow, Southcrn Nuclear Jim Andrachek, Westinghouse Jcrry Andrc, Westinghouse BWOG Paul Infangcr, Progress Energy Stanley Levinson, Framatome Mike Kitlan, Dukc 205 992-7037 412 374-5018 412 374-4723 352 563-4796 434 832-2768 980 373-8348 CEOG Alan Hackcrott, OPPD 402 533-7276 Gary Chung, SCE 949 368-9431 Ray Schneider, CE 860 731-6461 BWROG Fred Emerson, GE Dusty Rhoads, Energy Northwest 509 3774298 Page I of 7 4/21/2005 RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCIIEDULE/

TSTF NUMBER RESPONSIBILITY 2 Missed

  • Initiative Complete.

TSTF-358 R6 Surveillances SR approved and published for 3.0.3 CLIIP adoption.3 Increase Flexibility in

  • Initiative Complete.

TSTF-359 R9 Mode Restraints LCO approved and published for 3.0.4 CLIIP adoption.

.Revisions are needed to clarify the implementation guidance.

The TSTF will provide* The final Implementation the proposed changes to NEI in the second quarter Guidance, NEI-03-10, was of 2005.issued on September 5, 2003.4a Individual Risk

  • Owners Groups (OGs) are
  • Ongoing. TSTF-373 R2 (CEOG)Informed Completion pursuing generic Risk
  • TSTF-373R2 approved on 2/27/04.Times Informed Completion Time
  • TSTF-430R0 approved on 8/5/04. TSTF409 RI (CEOG)extensions through OG-

TSTF NUMBER I I RESPONSIBILITY I___4b Risk Informed Completion Times With Configuration Risk Management Program or Maintenance Rule Backstop* Hope Creek, Fort Calhoun, South Texas Project, and Prairie Island have volunteered to develop pilot submittals.

  • Fort Calhoun and South Texas Project have submitted their pilots.* The RITSTF is working to resolve the NRC's comments on the Risk Management Guidelines, the STP submittal, and the Traveler.* Action -Add description of Pilots* RITSTF will develop a White Paper to address the interface 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 will provide to NRC in 4/05.* NRC provided 3 separate RAIs in 8/04 to NEI.* The RITSTF has created an Initiative 4b Subgroup to coordinate responses to the NRC RAIs.* The RITSTF provided responses to the NRC and met to discuss these responses on 12/15/04.* NRC visited STP week of 1/18/05 to evaluate applications of Initiative 4b.* NRC and RITSTF met 3/17-18/05 to discuss policy issues. There will be another policy meeting 5/3-5/4, 2005. NRC will issue meeting summaries of these meetings.* The RITSTF is to provide a revised Risk Management Guideline document incorporating the results of the discussions by early 6/2005.* The NRC has requested that half of the April 21 RITSTF meeting be dedicated to Initiative 4b comments.* The NRC is reviewing the STP responses on the STP Pilot and will provide formal comments in 4/05.TSTF-424 RO 5a Relocate Surveillance
  • Deterministic portion of
  • TSTF reviewing candidate SRs to be relocated.

None assigned Requirements Not Initiative 5 transferred to Related to Safety TSTF responsibility.

  • TSTF will provide a TSTF to the NRC by 9/05.Page 3 of 7 4/21/2005 RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCIIEDULE/

TSTF NUMBER RESPONSIBILITY 5b Relocate Surveillance

  • RITSTF/BWROG/Pilot
  • NRC attended several Limerick IDP meetings to TSTF-425 RO Test Intervals to Plant will be applying the observe process.Licensee Control methodology and interfacing with the NRC
  • The Limerick lead plant license amendment was on the issues in 2004. submitted on 6/11/04.* TSTF-425 was submitted to the NRC on 8/31/04.* NEI provided the formal methodology document to the NRC on 2/3/05.* NRC reviewed the Limerick LAR, TSTF-425, and the methodology document and issued RAls 4/12/05 to the RITSTF.* A separate subcommittee is being formed by the RITSTF in response to the NRC's RAls and will have a meeting specific to Initiative Sb with the NRC.* The remaining RAIs should come out in early May 2005.* Meeting with NRC is scheduled for 6/1/05.6a Modify LCO 3.0.3
  • On hold.
  • On hold for resolution of Initiative 6b and 6c to None assigned Actions and Timing 1 determine if Initiative 6a is required.hour -24 hours Pagc 4 of 7 4/21/2005 RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

TSTF NUMBER RESPONSIBILITY 6b Provide Conditions in

  • NRC issued Safety
  • CEOG submitted revised version of Topical TSTF-426 RO the LCOs for Those Evaluation for Topical Report to address NRC RAls in 10/03.Levels of Degradation Report on 7/9/04.Where No Condition
  • NRC issued Safety Evaluation for Topical Report Currently Exists to
  • TSTF426 RO was submitted to the NRC on 8/30/04.* NRC provided an RAI on TSTF-426 on 11/13/04.* The TSTF has developed Implementation Guidance and responses to the NRC's RAIs and will provide these to the NRC in 5/05.* NRC plans to issue Notice for Comment July 2005.6c Provide Specific Times
  • NRC issued Safety
  • CEOG submitted revised version of Topical TSTF-426 RO in the LCO For Those Evaluation for Topical Report to address NRC RAIs in 10/03.Conditions That Report on 7/9104.Require Entry Into
  • NRC issued Safety Evaluation for Topical Report LCO 3.0.3 Immediately
  • TSTF-426 RO was on 7/9/04.submitted to the NRC on 8/30/04.
  • TSTF-426 RO was submitted to the NRC on 8/30/04.* NRC provided an RAI on TSTF-426 on 11/13/04.* The TSTF has developed Implementation Guidance and responses to the NRC's RAls and will provide these to the NRC in 5/05.* NRC plans to issue Notice for Comment July 2005.Pagc 5 of 7 4/21/2005 RITSTF INITIATIVE STATUS INITIATIVE I TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

TSTF NUMBER 1. L I RESPONSIBILITY I 7a Impact of Non Technical Specification Design Features on Operability Requirements

-Barriers* The NRC plans to issue the FRN Notice for Comment on TSTF-372, Rev. 4 in 3/05.o NRC providcd comments;on TSTF-427 on 11/13/04.* The NRC published the FRN Notice for Comment on TSTF-372 on 11/24/04.* The TSTF provided comments on the FRN Notice for Comment on 1/10/05.* The NRC is reviewing the TSTF comments and will work with the TSTF to revise the SE and issue the FRN Notice of Availability in early May 2005.* NRC provided feedback on RITSTF responses on TSTF-427 in February 2004.* TSTF/RITSTF will delete the additions to the definition of OPERABILITY for TSTF-427 to address NRC concerns.* TSTF-427 implementation guidance was provided to the NRC on 09/21/04.

NRC provided comments on the draft guidance on 10/13/04.* NRC provided an RAI on TSTF-427 on 11/13/04.* RITSTF provided responses to the NRC's RAIs on 3/23/05. The TSTF will provide a revision to TSTF-427 after completion of NRC review of the implementation guidance document and acceptance of the resolution of the NRC's RAls.* NRC is reviewing the RITSTF responses.

  • Plan is to resolve the technical issues by late June 2005 and issue Notice for Comment late July/early August 2005.TSTF-372 R4 TSTF-427 RO Page 6 of 7 4/21/2005 RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/

TSTF NUMBER RESPONSIBILITY 7b Impact of Non TS

  • A White Paper on the
  • RITSTF will develop a White Paper to outline the None assigned Design Features on process to address this process to address this scope of SSCs by 6/05.Operability scope of SSCs is being Requirements

-All developed.

  • RITSTF/TSTF reviewed and has commented on other SSCs not in the revised Operability guidance that will Technical supersede the guidance distributed with GL 91-18.Specifications
  • RITSTF/TSTF will develop a TSTF and submit to NRC by 12/05.8a Remove or Relocate
  • A White Paper on the
  • NEI 00-04 is being reviewed and will serve as the None assigned Systems LCOs That Do application of the 10 CFR basis for Criterion 4 application.

Not Meet the 4 50.36 criteria is being Criterion of 10 CFR developed.

  • RITSTF will develop a White Paper to outline the 50.36 From Technical guidance and methodology based on NEI 00-04 Specifications 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 third quarter 2005.8b Modify 50.36 Rule to

  • Requires Rulemaking
  • RITSTF looking at coordinating Initiative 8b with Not applicable Permit Removal or longer term initiatives given the requirements for Relocation of Non Risk rulemaking.

Significant Systems out of Technical

  • Approach favored by NEI and NRC is making Specifications Criterion 4 a "two way door" (e.g., if it doesn't meet Criterion 4, Specification can be relocated even if it meets Criteria 1, 2, or 3).BWOG -Active in Initiatives 1, 4 and 7 CEOG -Active in Initiatives 1, 4, 5 and 6 BWROG -Active in Initiatives 1, 4, 5 and 8 WOG -Active in Initiatives 1, 4, and 5 Page 7 of 7 4/21/2005 DISCUSSION TOPICS FOR APRIL 21, 2005, RITSTF MEETING ON INITIATIVE 4B RISK MANAGEMENT GUIDANCE DOCUMENT-Loss-of-Function/LCO 3.0.3 14b treatment; Industry to provide white paper-Operability vs Functionality

/ treatment of degradation

/ CCF: defined in RMG-Application of contingency plans, compensatory actions, and risk management actions-Process issues: i.e., actions following emergent events; shutdown; etc.-Is a risk ALARA rule/requirement appropriate?

-Referencing RMG in TS is necessary in Admin Controls Program-Uncertainty considerations

/ bounding assessments

-other issues Deferred items to May 3 & 4 Meeting with industry-Risk Metric requirements; what are they and are they needed in TS-Cumulative risk criteria, quantitative risk criteria Enclosure 5

White Paper Interface of RITSTF Initiative 4b and Initiative 6b/6c The Risk Informed Technical Specification Task Force (RITSTF) currently has several Risk Informed Initiatives in progress including Initiative 4b, "Risk Informed Completion Times With Configuration Risk Management Program or Maintenance Rule Backstop" and Initiative 6b/6c,"Provide Conditions in the LCOs for Those Levels of Degradation Where No Condition Currently Exists to Preclude Entry Into LCO 3.0.3" / "Provide Specific Times in the LCO For Those Conditions That Require Entry Into LCO 3.0.3 Immediately." Initiative 4b provides for extending the Completion Time beyond the existing Completion Time (known as the "front stop" Completion Time) for up to 30 days based on risk evaluations demonstrating the acceptability of this Risk Informed Completion Time (RICT) or extended Completion Time. The 30 day limit is known as the "back stop" Completion Time. This concept is currently envisioned to be applicable to all Conditions and the risk evaluation will govern whether or not part or all of the RICT may be utilized.Initiative 6b/6c provides Required Actions and Completion Times for those levels of degradation where no Condition is provided or where the Required Action is to enter LCO 3.0.3 immediately.

Many of the Conditions added by this Initiative represent a loss of safety function for the respective LCO. A loss of safety function is considered a condition in which the safety function provided by the structure, system, or component (SSC) cannot perform its specified safety function absent a single failure.Enclosure 6 I EXCEL Services Corporation White Paper Interface of RITSTF Initiative

41) and Initiative 6b/6c EXAMPLE 1 Assume a two train safety system.CONDITION REQUIRED ACTION COMPLETION TIME A. One train inoperable.

A.1 Restore train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.B. Two trains inoperable B.1 .Restore at least one train to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status.C. Required Action or C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> In general, there are three types of Conditions.

The first type of Condition represents a level of degradation with respect to the LCO, but the subject SSC can still perform its specified safety function assuming a single failure affecting the SSC does not occur. A typical example is Condition A of Example 1. The second type of Condition represents a level of degradation with respect to the LCO and the SSC cannot perform its specified safety function.

An example is Condition B of Example 1. The third type of Condition provides the Required Actions to be followed if other Required Actions or their associated Completion Times are not met. This is called the default Condition and is illustrated by Condition C of Example ].Required Action A. 1 of Example I has a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time. Under Initiative 4b, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is the front stop Completion Time. Initiative 4b would add a second back 2 EXCEL Services Corporation White Paper Interface of RITSTF Initiative 4b and Initiative 6b/6c stop Completion Time of 30 days. The Required Actions would also be modified to require a contemporaneous evaluation of plant risk and use of all or part of the 30 day back stop Completion Time would be dependant on an acceptable level of plant risk.Condition B of Example I is typical of the Action added by Initiative 6b/6c. Prior to Initiative 6b/6c, this Condition

-which represents a loss of function for the SSC that is the subject of the LCO -either would not have existed or would have directed immediate entry into LCO 3.0.3.Initiative 6b/6c demonstrated that in many cases the risk associated with this type of loss of safety function Condition did not warrant the immediate shutdown directed by LCO 3.0.3.The RITSTF believes that the 30 day back stop Completion Time of Initiative 4b should be applied to the Conditions added or modified by Initiative 6b/6c or similar existing Conditions.

The contemporaneous risk assessment required by Initiative 4b will dictate whether operation beyond the front stop Completion Time is permitted.

Initiative 6b/6c has already demonstrated that the plant conditions represented by the modified Actions represent low risk configurations.

It is appropriate to utilize those insights to allow continued plant operation up to the back stop Completion Time if the configuration continues to represent low plant risk The RITSTF does not believe that the 30 day back stop Completion Time of Initiative 4b should be applied to the default condition, as illustrated by Condition C in Example 1. The default Condition is entered if either the Required Actions cannot be performed or if the Completion Time has been exceeded.

The most common reason for entering the default Condition is the expiration of the Completion Time of the other Required Actions. If Initiative 4b is applied to the other Conditions 3 EXCEL Services Corporation White Paper Interface of RITSTF Initiative 4b and Initiative 6b/6c (for example, Conditions A and B of Example 1), then either the plant risk does not support continued use of the Completion Time beyond the front stop Completion Time or the 30 day back stop Completion Time has been reached. In either case, providing an additional 30 day risk informed back stop Completion Time is not appropriate because it either could not be justified by plant risk or would represent an extension of the 30 day back stop Completion Time of the other Conditions.

Conclusion It is appropriate to apply the Initiative 4b back stop Completion Time concept to Conditions added or modified by Initiative 6b/6c and to allow the contemporaneous risk assessment to manage plant risk to acceptable levels. The RITSTF does not support applying the Initiative 4b back stop Completion Time concept to default Conditions.

4 EXCEL Services Corporation

Retrieved from "https://kanterella.com/w/index.php?title=ML051450421&oldid=1061821"