ML042580010

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Enclosure 4 Risk Informed Technical Specification Task Force (RITSTF) Risk Management Technical Specification Initiative Status
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)


Text

RISK INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)

RISK MANAGEMENT TECHNICAL SPECIFICATION INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 1 Technical Specification

  • Industry and NRC
  • A draft of the TSTF-422 implementation guidance BWOG - TSTF-431 R0 document was provided to the NRC for comment in 6/04. NRC provided comments on 7/9/04 and a WOG - TSTF-432 R0 revised document has been developed to address (Not created) these comments. The document will be submitted to NRC by 9/20/04.
  • NRC will attempt to issue TSTF 422 Notice for Comment and Availability in 2004.
  • 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.
  • A draft of the TSTF-423 implementation guidance document 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 BWROG TSTF 423 Implementation Guidance.
  • Based on review of the CEOG TSTF 422 Implementation Guidance, the NRC will provide the scope of additional information they want to BWROG.

NEI RITSTF NEI Biff Bradley, 202 739-8083 WOG Jack Stringfellow, Southern Nuclear, 205 992-7037 CEOG Alan Hackerott, OPPD, 402 533-7276 Tony Pietrangelo, 202 739-8081 Jim Andrachek, Westinghouse, 412 374-5018 Gary Chung, SCE, 949 368-9431 EXCEL/

TSTF Donald Hoffman, 301 984-4400 Jerry Andre, Westinghouse, 412 374-4723 Ray Schneider, CE, 860 731-6461 EPRI Frank Rahn, 650 855-2037 BWOG Paul Infanger, Progress Energy, 352-563-4796 BWROG Rick Hill, GE, 408 925-5388 John Gaertner, 704 547-6169 R. Schomaker, Framatome, 434 832-2917 Dusty Rhoads, Energy Northwest, 509 377-4298 Mike Kitlan, Duke, 980 373-8348 Don McCamy, TVA 256 729-4595 Page 1 of 2 9/09/2004

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 1 Technical Specification

  • Industry and NRC
  • BWOG Topical Report was submitted to NRC on CEOG - TSTF-422 R0 Required Actions developing implementation 1/19/04. The NRC provided an RAI on 6/29/04.

Preferred End States guidance for TSTF-422 and BWOG informed the NRC they could not respond BWROG - TSTF-423 R0 TSTF-423. to the RAI until early 2005, and the NRC has put review of the Topical Report on hold. BWOG - TSTF-431 R0

Page 2 of 2 9/09/2004

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 2 Missed Surveillances

3 Increase Flexibility in

  • Initiative Complete. TSTF-359 R9 Mode Restraints LCO approved and published for 3.0.4 CLIIP adoption.
  • The final Implementation Guidance, NEI-03-10, was issued on September 5, 2003.

4a Individual Risk

  • Owners Groups (OGs) are

Informed Allowed pursuing generic Risk Outage Times (AOTs) Informed AOT extensions TSTF-409 R1 (CEOG) through OG-specific Topicals and license TSTF-417 R0 (WOG) amendments.

TSTF-430 R0 (BWOG)

TSTF-439 R1 (ALL OG)

TSTF-446 R0 (WOG)

TSTF-454 R0 (BWROG)

Page 3 of 2 9/09/2004

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 4b Risk Informed AOTs Hope Creek, Fort Calhoun, TSTF-424 R0 With Configuration South Texas Project, and Prairie

  • RITSTF will develop a White Paper to address the Risk Management Island have volunteered to interface of the a.4 process to the Initiative 4b and Program or develop pilot submittals. Initiative 6 process to show the overlap and Maintenance Rule transition for ITS and non ITS plants and provide Backstop Fort Calhoun and South Texas to NRC in October 2004.

Project have submitted their pilots.

  • 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.
  • Current schedule is to provide responses to NRC and meet in 12/04.

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 12/04.

5b Relocate Surveillance

  • RITSTF/BWROG/Pilot TSTF-425 R0 Test Intervals to Plant will be applying the
  • NRC attended several Limerick IDP meetings to Licensee Control methodology and observe process.

interfacing with the NRC on the issues in 2004.

  • The Limerick lead plant license amendment was submitted on June 11, 2004.
  • TSTF-425 was submitted to the NRC on 8/31/04.
  • NEI is preparing the methodology document for submittal to the NRC in 09/04.

Page 4 of 2 9/09/2004

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 6b Provide Conditions in

  • NRC issued Safety
  • CEOG submitted revised version of Topical TSTF-426 R0 the LCOs for Those Evaluation for Topical Report to address NRC RAIs in 10/03.

Levels of Degradation Report on 7/9/04.

Where No Condition

  • NRC issued Safety Evaluation for Topical Report Currently Exists to

Preclude Entry Into submitted to the NRC on LCO 3.0.3 8/30/2004.

  • TSTF-426 R0 was submitted to the NRC on 8/30/04.
  • RITSTF submit draft Implementation Guidance in 11/04.

6c Provide Specific Times

  • NRC issued Safety
  • CEOG submitted revised version of Topical TSTF-426 R0 in the LCO For Those Evaluation for Topical Report to address NRC RAIs in 10/03.

Conditions That Report on 7/9/04.

Require Entry Into

  • NRC issued Safety Evaluation for Topical Report LCO 3.0.3 Immediately

submitted to the NRC on 8/30/2004.

  • TSTF-426 R0 was submitted to the NRC on 8/30/04.
  • RITSTF submit draft Implementation Guidance in 11/04.

Page 5 of 2 9/09/2004

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 7a Impact of Non

  • Draft Revision 4 of TSTF-372 created on 2/24/03. TSTF-372 R4 Technical Specification submitted on 4/23/04. NRC reviewed and agreed it addressed their Design Features on comments. TSTF-372, Rev. 4 submitted to NRC TSTF-427 R0 Operability

Requirements - Barriers 3/4/03.

  • On 5/28/04, the NRC requested additional
  • NRC provided comments information to support review of TSTF-372. The on TSTF-427 on 6/26/03. TSTF/RITSTF responded on 6/7/04.
  • NRC requested additional information in 7/04 and Industry/NEI responded with responses 9/7/04.
  • 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 being developed and will be provided to the NRC by 09/17/04.
  • TSTF/RITSTF will provide a revision to TSTF-427 after completion of the implementation guidance document.

Page 6 of 2 9/09/2004

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 scope process to address this scope of SSCs by 10/04.

Operability of SSCs is being developed.

Requirements - All

  • 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 12/04.

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 fourth quarter 2004.

Page 7 of 2 9/09/2004

RITSTF INITIATIVE STATUS INITIATIVE TITLE INITIATIVE STATUS NEXT ACTIONS/SCHEDULE/ TSTF NUMBER RESPONSIBILITY 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 doesnt 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 8 of 2 9/09/2004