ML090160113

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Pre-Application Meeting Re. a Future Amendment to Convert the Technical Specifications to ITS Format
ML090160113
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 01/15/2009
From:
- No Known Affiliation
To:
Office of Nuclear Reactor Regulation
Peter Tam, NRR/DORL 415-1451
References
TAC ME0247
Download: ML090160113 (1)


Text

Kewaunee Conversion Pre-Submittal Meeting IT8B Topics for Discussion Based on internallTSB discussions of lessons learned from previous Tech Spec Conversions including Davis Bessie (18-19 Dec. 2008)

Preparation of Submittal

  • The completeness and complexity (or simplicity) of the submittal affects evaluation process
  • Submittal letter must confirm that the CD is equivalent to hard copy
  • STS 3.0 is the latest version and basis for conversion, not 3.1
  • List all TSTF's adopted that are not incorporated into STS Revision 3.0

---t List all TSTF's adopted in which all aspects of the TSTF were not followed (l.e.

deviations, not adopting commitments, etc)

  • All submittals should state if a commitment or license condition has been added modified or deleted
  • Identification of Beyond Scope Items (BSI)

---t Current Licensing Basis

---t Definition

-+ Review of CLB during Conversion evaluation Review Process Overview and Lessons Learned

  • Describe typical stages and schedule
  • Definition and impact of "Beyond Scope Items" (BSI)

---t They are generally characterized as changes that differ from both the existing technical specifications and the improved STS

---t As defined in NRC Administrative Letter 96-04, BSls are those changes to the technical specifications that are not directly related to the conversion amendment.

---t NEI 96-06, Improved Technical Specifications Conversion Guidance, similarly identifies BSls as changes, such as plant-specific risk-based changes and power uprates, which are considered beyond the scope of the ITS conversion application and therefore may result in delays in ... approval of the application.

  • Use of Bases during review
  • Use of RAl's during review
  • Use of Current Licensing Basis during review
  • Items requiring Technical Branch Review

---t List of examples Other Items

  • Plant responsiveness

---t Effect of refueling outages during evaluation period? .

---t Timely and thorough

  • Applicability of precedent
  • Ongoing reviews of TSTF's can impact conversion
  • Use of Excel Services Database

---t Used for both informal questions and information requests

---t Unresolved issues may elevate quickly to RAI's