B12809, Application for Amend to License DPR-21,adding License Condition Re Integrated Implementation Schedule. Millstone Nuclear Power Station,Unit 1,Integrated Implementation Schedule Program Plan Encl.Fee Paid

Application for Amend to License DPR-21,adding License Condition Re Integrated Implementation Schedule. Millstone Nuclear Power Station,Unit 1,Integrated Implementation Schedule Program Plan Encl.Fee Paid

ML20148K581
Person / Time
Site:	Millstone
Issue date:	03/24/1988
From:	Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20148K585	List: B12809, Application for Amend to License DPR-21,adding License Condition Re Integrated Implementation Schedule. Millstone Nuclear Power Station,Unit 1,Integrated Implementation Schedule Program Plan Encl.Fee Paid ML20148L815
References
B12809, NUDOCS 8803310207
Download: ML20148K581 (7)

Text

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< , e March 24, 1988 Docket No. 50-245 B12809 Re: Integrated Safety Assessment Program U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 i Gentlemen:

Millstone Nuclear Power Station, Unit No. 1 Integrated Implementation Schedule License Amendment Pursuant to 10CFR50.90, Northeast Nuclear Energy C- npany (NNECO) hereby requests an amendment to Facility Operating License DPR-21 for Millstone Unit d No. 1. The proposed amendment would add a license condition requiring NNECO to implement and maintain its Integrated Implementation Schedule (IIS) Program Plan (the Program Plan). The Program Plan provides a methodology to be I followed for scheduling plant modifications and engineering evaluations. This license amendment application involves no significant hazards consideration.

DISCUSSION In a letter dated August 4, 1987,(I) NNEC0 submitted its initial IIS for Millstone Unit No. 1. This initial IIS was a direct result of NNEC0's Integrated Saf Assessment Program (ISAP) described in a letter dated July 31,1986.gtg The initial IIS included completion dates for all currently planned plant modifications, plant-improvement projects, and engineering evaluations of well-defined scope. These activities generally address the Millstone Unit No. 1 ISAP topics and were scheduled based in part on their relative ISAP rankings.

NNECO now plans to formalize its methodology for developing and updating the Millstone Unit No. 1 IIS. As discussed in the August 4, 1987 letter, NNEC0 is hereby proposing a license condition to be added to the Millstone Unit No. 1 (1) E.J. Mroczka letter to U.S. Nuclear Regulatory Commission, "Integrated Safety Assessment Program," dated August 4, 1987.

(2) J.c. Opeka letter to C.I. Grimes, "Integrated Safety Assessment Program -

Final Report for Millstone Unit No. 1," dated July 31, 1986.

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U.S. Nuclear Regulatory Commission B12809/Page 2 March 24, 1988 operating license, requiring that the IIS be developed and maintained consis-tent with an NRC-approved IIS Program Plan. The proposed license condition is provided in Attachnent I.

NNEC0's approach is different in concept from "integrated living schedules" at some other nuclear power plants. Under NNEC0's approach, the Program Plan is being submitted for NRC review and approval. However, the specific implemen-tation schedules for each topic will not be fixed by license amendment. NNEC0 believes that its approach is less cumbersome than alternate approaches, allowing the licensee sufficient flexibility in scheduling projects and in updating the schedule as necessary. The Program Plan in turn provides a consistent methodology and provides for NRC oversight in order to assure the integrity of the IIS process. The Program Plan is provided in Attachment II.

Essentially, under the Program Plan, ISAP serves as NNEC0's prioritization methodology for developing the IIS. However, the Program Plan inherently recognizes that the ISAP methodology is evolving and will be refined for future revisions of the IIS. Further, in addition to the ISAP rankings, other considerations such as resource availability, outage duration, and ALARA goals must be factor ei into the IIS development process on a principled basis. The Program Plan provides the framework for this analysis.

The Program Plan also specifically provides for NRC oversight of the IIS. The Program Plan describes the responsibilities of NNEC0 with respect to submit-ting the IIS to the NRC; describes the mechanisms for updating the IIS and reporting to the NRC; and describes the mechanism for changing the Program Plan itself.

The IIS will incorporate: 1) activities mandated by NRC rules, orders, and license conditions; 2) regulatory items ider.tified by the NRC, resulting in

, plant modifications, procedure revisions, or changes in staffing requirements; l 3) prospective NRC requirements, or tasks mandated by other agencies; and 4) licensee-identified changes for operational improvement. The IIS may also

( incorporate other ongoing NNEC0 projects that require significant resource commitments.

Generally, under the Program Plan, if an implementation date for an activny is fixed by NRC regulation or order, NNEC0 will meet that date or seek an appropriate exemption to support a later date in the IIS. Otherwise, all implementation dates will be set by the ISAP/IIS methodology described in the Program Plan. Provisions in the Program Plan address changes to the schedule I to accommodate newly identified activities, unforeseen circumstances, or new NRC requirements.

In summary, NNEC0 believes this scheduling process provides a coherent and consistent basis for enhancing nuclear power plant safety and operation. As has been the case with ISAP, the IIS process is by necessity an interactive l one between NNEC0 and the NRC Staff.

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1 U.S. Nuclear Regulatory Commission B12809/Page 3 March 24, 1988 SIGNIFICANT HAZARDS CONSIDERATION The proposed license amendment to add the IIS licensa condition to the Millstone Unit No. 1 operating license involves no significant hazards consid-eration. The proposed license amendment adds a license condition to the Millstone Unit No. 1 operating license to require implementation of the IIS Program Plan. The purpose of the Program Plan is to describe NNEC0's method-ology to develop a plant-specific plant improvement schedule for Millstone Unit No. I based in part on the prioritization methodology of ISAP.

The IIS resulting from the process described in the Program Plan, and required by the proposed license condition, will be NNEC0's controlling schedule for implementing all modifications and engineering evaluations of a well-defined scope for Millstone Unit No. 1. This includes activities sdentified to address NRC regulatory issues as well as activities identified by NNEC0 to enhance safe, reliable, and economic operation of the plant. The IIS process described in the Program Plan is intended to assure that in scheduling imple-mentation of these projects and studies, available (and finite) resources are devoted to the extent practicable in a prioritized and cost-effective manner.

The Program Plan specifically describes the ISAP prioritization methodology, the mechanism for addressing other "real-world" scheduling constraints, the mechanism for updating the IIS to reflect new issues and new circumstances, NNEC0's periodic reporting requiremen'.s . NRC oversight, and the mechanism for updating the Program Plan itself.

Although the proposed license amendment will not incorporate specific imple-mentation dates for each topic, NNEC0's IIS Program Plan will assure a consis-tent and principled scheduling process with appropriate NRC oversight. In summary, through ISAP and the IIS, NNECO intends to optimize allocation of resources available for enhancing nuclear power plant safety and operation.

In 10CFR50.92(c), the NRC has provided standards for determining whether a significant hazards consideration is involved in a license amendment applica-tion. By applying these standards, NNECO concludes that this amendment involves no significant hazards considerations.

< l. Operation of the facility in accordance with this proposed change will nqt involve a significant increase in the probability or consequences of any accident previously evaluated.

The proposed change would require the implementation of the IIS methodol-gy described in the Program Plan. As such, it requires that NNEC0 establish an administrative means for tracking, prioritizing, and sched-uling NRC-required plant modifications and engineering evaluations, and licensee-identified plant improvement projects. This methodology is intended to enhance plant safety by more effectively controlling the number and scheduling of plant modifications, tnereby assuring that i

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U.S. Nuclear Regulatory Commission B12809/Page 4 March 24, 1988 issues required for safe operation of the plant receive priority and are completed in a timely manner.

Because the license condition addrestes only an administrative scheduling mechanism, it does not affect directly the design or operation of the plant. Therefore, no accident analyses are affected and the proposed change does not increase the probability or consequences of any previous-ly evaluated accident.

2. Operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

As discussed above, the proposed license condition establishes a new requirement relating to scheduling of modifications and engineering evaluations. Therefore, the proposed change does not create the possi-bility of a new or different kind of accident from any previously evalu-ated.

3. Operation of the facility in accordance with this proposed change will nqt involve a significant reduction in any margin of safety.

As discussed above, the ps oposed license condition establishes a new administrative requirement intended to enhance public safety and reliable plant operation. It does not affect any accident analysis or involve any modification to the plant configuration or operation. Therefore, the proposed change does not involve a reduction in any margin of safety.

The Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7751, March 6, 1986). The proposed amendment most closely resembles example (ii), a change that consti-tutes an additional limitation, restriction, or control not presently included in the technical specifications (e.g., a more stringent surveillance require-ment), in that the proposed license amendment would require the implementation

, of the IIS Program Plan (not currently required) for the scheduling of plant l modifications and well-defined engineering evaluations, i

In accordance with 10CFR50.91(b)(1), a copy of this amendment request is being forwarded to the State of Connecticut.

l Although this license amendment is not required for continued plant operation, i

NNEC0 recognizes the benefits of this program and therefore requests that the Staff act on this application in a timely manner.

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I V.S. Nuclear Reguiatory Commission B12809/Page 5 March 24, 1988 Pursuant to the requirements of 10CFR170.12(c), enclosed with this license amendment request is the application fee for $150.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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E.Wflfr6czka f/'

Senior Vice President cc: W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No.1 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT)

) ss. Berlin COUNTY OF HARTFORD )

Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.

p7Asd Notary Pubfjt kh i W Commiss!on Exp.!res March 31,1988 l

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Docket No. 50-245 B12809 Attachment I Hillstone Nuclear Power Station, Unit No.1 Proposed License Condition March 1988

IIS License Condition 2.C(5) Intearated Imolementation Schedule

a. Northeast Nuclear Energy Company shall implement and main-tain in effect the Integrated Implementation Schedule Program Plan (the Program Plan) to be followed for schedul-ing of plant modifications and engineering evaluations. The Program Plan shall be followed from and after the effective date of this license condition.

b. This license- condition shall be effective until (date of approval of amendment by NRC plus three years),

subject to renewal upon application by the licensee.

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