ML011160514

License Amendment No. 122, Incorporation of Requirements to Adhere to the Plan for the Long Range Planning Program

ML011160514
Person / Time
Site:	Oyster Creek
Issue date:	05/27/1988
From:	Dromerick A Office of Nuclear Reactor Regulation
To:	Fitzpatrick E GPU Nuclear, New Jersey Central Power & Light Co
References
-RFPFR, 64687 NUDOCS 8806170035
Download: ML011160514 (28)

Text

May 27, 1988 DISTRIBUTION Docket Docket No. 50-219 NRC A Local PDRs PDI-4 RF SAVarga BABoger SMNorri s Mr. E. F. Fitzpatrick ADromerick Vice President and Director OGC ACRS (10)

Oyster Creek Nuclear Generating Station DHagan GPA/PA Post Office Box 388 EJordan ARM/LFMB Forked River, New Jersey 08731 JPartlow Gray File TRarnhart (4ý

Dear Mr. Fitzpatrick:

Wanda Jones EButcher

SUBJECT:

ISSUANCE OF AMENDMENT (TAC NO. 64687) Tech Rev. Br.

The Commission has issued the enclosed Amendment No.122 to Provisional Operating License Nc. DPR-16 for the Oyster Creek Nuclear Generating Station, in response to your application dated January 27, 1987, as supplemented March 16, 1988.

The amendment (Enclosure 1) incorporates the requirement to adhere to the "Plan for the Long Range Planning Program for the Oyster Creek Nuclear Generating Station" (the Plan) and the terms therein for implementing changes to its contents.

The staff's evaluation of the Plan is provided in Enclosure 2 and a copy of the current Plan (including current issues) is enclosed in Attachments . and ? of Enclosure 2. The staff has reviewed the Plan and the current issues and has found them to be acceptable.

The Commission has previously issued Orders to the licensees of operating reactors, confirming their schedules for compliance to various requirements (e.g., Emergency Response Capability, etc.). The Commission has also issued and will continue to issue Generic Letters, Bulletins and Notices on various technical issues. Some of these documents have required significant action be taken by the facility management to modify plant equipment and procedures in order to enhance overall plant safety. The procedures used in the Plan, which you are required to follow, have been developed to improve the method of assuring that required plant modifications, including significant modifications required by the Commission, are completed in a more systematic and timely fashion. We also anticipate that the resulting improvement in control and management of available resources will facilitate plant modification efficiency and effectiveness.

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Mr. F. F. Fitzpatrick -2 -

The notice of issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, original signed by Alexander W. Dromerick, Project Manager Project Directorate 1-4 Division of Reactor Projects T/Il Office of Nuclear Reactor Regulation

Enclosures:

1. Amendment No. 122to OPR-16

2. Safety Evaluation cc w/enclosures:

See next page PPI-4 PDI-4 1 SNo s .'sah Aflromeri c X/I C/88

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Fr. E. E. Fitzpatrick Oyster Creek Nuclear Oyster Creek Nuclear Generating Station Generating Station cc:

Ernest L. Blake, Jr. Resident Inspector Shaw, Pittiran, Potts and Trowbridge c/o U.S. NRC 2300 N Street, NV Post Office Box 445 Washington, D.C. 20037 Forked River, New Jersey 0E731 J.9. Liberman, Esquire Commissioner Bishop, Liberman, Cook, et al. New Jersey Cepartment of EnerGy 1155 Avenue of the Americas 101 Commerce Street New York, New York 10036 Newark, New Jersey 071C2 Mr. David V. Scott, Chief Regional Administrator, Region I Bureau of Nuclear Engineering U.S. Nuclear Regulatory Comminssior Department of Environmental Protection 475 Allendale Road CN 411 King of Prussia, Pennsylvania 19406 Trenton, New Jersey 086.5 BVP Licensing Manager GPU Nuclear Corporation I Upper Pond Road Parsippany, New Jersey 07054 Deputy Attorney General State of New Jersey Departmnent of Law and Public Safety 36 West State Street - CM 112 Trenton, New Jersey 08625 Mayor Lacey Township r18 West Lacey Road Forked River, New Jersey 08731 Licensing Manager Oyster Creek Nuclear Generating Station Mail Stop: Site Emergency Bldg.

P. 0. Box 388 Forked River, New Jersey 08731

,V REO(,

0 UNITED STATES 0

NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 0

C, GPU NUCLEAR CORPORATION AND JERSEY CENTRAL POWER & LIGHT COMPANY DOCKET NO. 50-219 OYSTER CREEK NUCLEAR GENERATING STATION AMENDMENT TO PROVISIONAL OPERATING LICENSE Amendment No. 122 License No. DPR-16

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by GPU Nuclear Corporation et al.,

(the licensee), dated January 27, 1987, as supplemented March 16, 1988 complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commilss ion; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, Provisional ODeratinq License No. DPR-16 is amended by adding paragraph 2.C.(10) to read as follows:*

(10) Long Range Planning Program The "Plan for the Long Range Planning Program for the Oyster Creek Nuclear Generating Station" (the Plan) submitted by GPIJ Nuclear Corporation letter C 311-88-2030 dated March 16, 1988 is approved.

a. The Plan shall be followed by the licensee from and after May 27, 1988.

b. The Cateaory A schedule shall not be changed without prior approval from the NRC. Categories B and C schpdules may be changed without prior approval by the NRC.

3. This license amendment is effective as of the date of issuancp.

FOR THE NUCLEAR REGULATORY COMMISSION John .Stolz, Director

/ 2 Project Directorate 1-4 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Pate of Issuance: May 27, 1988

• Pacp 5 is attached, for convenience, for the composite license to reflect this change. Remove pages 4a and 5.

2. C. (9) The requirements described in the Attachments to the Commission's Order dated March 14, 1983, for NUREG-0737 Item II.K.3.19, Interlock on Recirculation Pumps, are changed to an alarm in the control room to indicate that a fourth recirculation loop has been isolated and an alarm reflash to indicate that a fifth loop has been isolated. The schedule for implementing this requirement, including writing the procedures to use the alarm and training the operators, is the same schedule in the Commission's Order dated March 14, 1983. This schedule for implementation is prior to the restart from the Cycle 11 refueling outage. This license condition was expanded to include the schedule for implementation.

2. C. (10) Long Range Planning Program The "Plan for the Long Range Planning Program for the Oyster Creek Nuclear Generating Station" (the Plan) submitted by GPU Nuclear Corporation letter C 311-88-2030 dated March 16, 1988 is approved.

a. The Plan shall be followed by the licensee from and after May 27, 1988.

b. The Category A schedule shall not be changed without prior approval from the NRC. Categories B and C schedules may be changed without prior approval by the NRC.

3. The effectiveness of this amended license is encompassed within the effective period which has been specified for the existing license: This license is effective as of the date of issuance and shall expire at midnight April 9, 1972.

4. This license amendment shall become effective January 1, 1982.

FOR THE NUCLEAR REGULATORY COMMISSION

/s/ Walter A. Paulson - for Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing

• The license remains effective since a timely application dated March 6, 1972, has been filed for a Full Term License.

Attachment:

Changes to the Technical Specifications Date of Issuance: December 29, 1981 Amendment No. - , 122 i

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 I' o ENCLOSURE 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.122 TO PROVISIONAL OPERATING LICENSE NO. DPR-16 GPU NUCLEAR CORPORATION AND JERSEY CENTRAL POWER & LIGHT COMPANY OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219

1.0 INTRODUCTION

By letter dated January 27, 1987, and supplemented March 16, 1988.

GPU Nuclear Corporation (GPUN, the licensee) submitted an application to amend the Oyster Creek Nuclear Generating Station, Provisional Operating License No. DPR-16, to incorporate the requirement to adhere to the "Plan for the Long Range Planning Program for the Oyster Creek Nuclear Generating Station" (OCNGS). In the licensee's submittal of March 16, 1988, the licensee made several minor plan changes in response to the staff's reauest. The licensee also made a minor change to the proposed license condition. The information submitted by letter dated March 16, 1988 provided clarification of the January 27, 1987 submittal.

The Program was developed by GPUN to enable GPUN to effectively manage implementation of significant changes to OCNGS which have been required, or proposed bv the NRC, as well as other measures to enhance plant safety and reliability which have been identified by GPUN or other agencies (e.g, the Institute for Nuclear Power Operations).

The primary program objectives are to (1) optimize the allocation of GPUN and NRC resources to those projects necessary to assure safe, reliable, and economic plant operation and (2) achieve the appropriate balance and prioritization among all proposed projects based on their relative value and effect regardless of source.

The "Plan for the Long Range Planning Program for the Oyster Creek Nuclear Generating Station" (Attachment 1) is the implementation vehicle for the Long Range Planning Program. The Plan describes how the program functions, mechanisms for changing the program and updating it, the interactions and responsibilities of the NRC and licensee staffs under the program, and its resultant assessments and schedules. The format and content of this Plan closely follows the previously approved Big Rock Point Plan.

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2.0 EVALUATION 2.1 Plan Description The OCNGS Long Range Planning Program is based on a list of over 50 major projects and their completion dates each of which is assigned a priority resulting from an established assessment method. In general, this list will exclude minor capital and specific Operations and Maintenance funding requests (under $50,000) unless the project could have a critical impact on major planned activities (e.g., inspections with potential for adverse contingencies) or is mandated by the NRC. The assessment method involves ranking each project based on its importance relative to public safety (e.g., safe shutdown, radiological release potential), personnel safety, plant availability/capacity factor and economic incentive.

The scheduling of major projects takes into account projections for budgets and site manpower and engineering support reauirements for up to five years, on an item-by-item basis covering all major plant projects.

The Plan submitted by the licensee organizes the projects into Categories A, B and C based upon their origin. Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recovery plans. The three categories are described below:

Category A - All projects involving regulatory issues which have resolution dates mandated by NRC rules, orders or license conditions.

Category B - Projects involving issues identified by the NRC and/or GPUN for which commitments have been made to the NRC by GPUN.

The issue resolutions would result in significant (a) plant modifications, (b) procedure revisions, or (c) changes in facility staffing requirements.

Category C - Other major projects, identified by GPUN or other regulatory agencies.

The Plan recognizes that projects, project scopes, and scheduled completion dates will need to be modified or deleted at times to reflect changes in regulatory requirements to accommodate those activities that GPUN finds necessary to improve plant efficiency and reliability, to incorporate the results of investigation into issues, and to take into account delays resulting from events beyond the licensee control.

2.2 Plan Implementation The licensee's January 27, 1987 submittal (as supplemented March 16, 1988) incorporates a license condition requiring that GPUN follow the Plan and permits the licensee to make changes to the Plan and its issue resolutions and schedule for certain categories of issues in accordance with the provisions of the Plan. The staff has reviewed the licensee's Plan and has determined that:

1. Changes to issue resolutions and/or schedules for completion of major issues imposed by rule, order or license condition (Category A projects) will require prior NRC approval.

2. Issue resolutions and/or schedules for completion of major issues by the NRC and/or GPUN for which commitments have been made to NRC by GPUN (Category B projects) are identified and provisions are made in the Plan to require GPUN to provide the NRC with notification of changes to Category B projects.

3. Schedules for completion of other major projects identified by GPUN or other regulatory agencies (Category C projects) are identified and provisions are made in the Plan to require GPUN to notify NRC on a semi-annual basis of changes, deletions or scheduling of Category C projects.

4. Provisions are made in the Plan for incorporating new or anticipatory major issues into Category A and B as these issues are identified by NRC and/or formalized by rule, order or license condition.

The licensee identified each planned major NRC-required modification and major non-NRC modification as an individual line item in its list of Category Projects. Semi-annual reports of licensee progress towards implementation of NRC-identified and licensee-identified modifications are proposed by the licensee.

The licensee's proposal to incorporate a condition into the Oyster Creek provisional operating license provides an appropriate mechanism to ensure that the NRC is informed as to whether required safety-related issues are being completed in a timely manner. The Plan also provides a suitable mechanism for changes to completion dates (due to unforeseen circumstances) for modifications not imposed by rule or order and for keeping the NRC informed of such changes for its consideration. Thus, the degree of flexibility needed to assure effective program implementation is provided while at the same time ensuring the the NRC's responsibilities are not compromised.

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The Plan and the proposed license condition submitted by the licensee are functionally identical to those approved by the staff in Amendment No.

82 to the Big Rock Point Plant operating license, Amendment No. 75 tc the Pilgrim Nuclear Power Station operating license and Amendment No. 91 to the Duane Arnold Energy Center (DAEC) operating license. A copy of Amendment No. 91 was transmitted to all power reactor licensees by Generic Letter 83-2C on May 9, 1983. This letter identified the approach addressed by Amendment No. 91 as one which is acceptable to the NRC.

Therefore, the staff has determined that (1) the Plan proposed by GPUN is equivalent to a previously approved plan, and (2) the license condition proposed by GPUN is equivalent to the previously approved license condition for Big Rock Point Plant on this subject.

2.3 Proposed Issues and Schedules Attachment 2 to this enclosure provides GPUN's proposed list of major projects and schedules for completion of presently known GPUN-planned and NRC-required modifications.

For modifications imposed by rule or order, the utility proposes completion by the required dates, or has received an approval from the NRC for an extension of the deadline (e.g., Installation of Torus Temperature Instrumentation and Temperature indication recorded in the control room extension cf deadline from refueling outage h]R to refueling outage 12R).

GPUN has proposed completion of other GPUN and NRC initiated modifications not required by rule or order on a schedule consistent with its previous commitments. As a sample, significant regulatory issues in this category include installation of cathodic protection system to arrest or mitigate identified corrosion of the drywell wall and replacement of nylon type relays with Century Tefzel Bobbin Type Relays. Based on our review of these projects and the remaining existing projects not listed above, we find the dates proposed by the licensee for completion of these modifi cations to be acceptable.

2.4 Summary Based on the considerations addressed herein, we find that:

1. The proposal by GPUN, that its Plan be implemented by a license condition requiring the licensee to follow the Plan, is acceptable.

2. The licensee's proposal stating that changes to implementation dates imposed by rule, orders or license conditions will require prior NRC approval is acceptable.

3. Based upon our review, the completion dates proposed by the licensee in the submittal are reasonable.

4. The license condition and the Plan submitted by GPUN are equivalent to that already approved in Amendment No. 82 to the Big Rock Point Plant.

5. GPUN and NRC should be cognizant that there are likely to be higher priority and more urgent safety issues that are not included in the list because the projects do not exceed the threshold cost of $50,000 or are not mandated by the NRC. The licensee tracks these safety issues using the GPUN licensing action item system for the OCNGS.

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assess ment need be prepared in connection with the issuance of this amendment.

4.0 CONCLUSION

The staff has concluded, based on-the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to the common defense and security nor to the health and safety of the public.

Dated: May 27, 1988 Principal Contributor: Alexander W. Dromerick Attachments:

1. Plan for the Long Range Planning Program

2. List of Major Projects and Schedules

ATTACHMENT 1 PLAN FOR THE LONG RANGE PLANNING PROGRAM FOR THE OYSTER CREEK NUCLEAR GENERATING STATION I. INTRODUCTION GPU Nuclear Corporation (GPUN) has developed a comprehensive program which will enable GPUN to effectively manage implementation of significant changes to the Oyster Creek Nuclear Generating Station (O.C.)

which have been required, or proposed by, the NRC, as well as other measures to enhance plant safety and reliability which have been identified by GPUN or other agencies (e.g., the Institute of Nuclear Power Operations). The program is identified as the "GPUN Long Range Planning Program". This program was developed to assess, coordinate and schedule major work tasks or projects at O.C., including those manda:ed or proposed by the NRC, or identified by GPUN and others. The program objectives are to (1) satisfy regulatory requirements; (2) provide sufficient lead times for modifications; (3) minimize changes for operators; (4) effectively manage financial and human resources; and (5) specify the framework for changes to developed projects and associated schedules. This will be accomplished within the overall objective of plant safety and availability.

This program reflects the recognition by GPUN and the NRC that fiscal and manpower resources are finite and that a limit on the onsite manpower is necessary. Routine functional plant operations and maintenance require a substantial portion of available resources, further limiting resources which can be applied to the resolution of non-routine but important regulatory and non-regulatory issues that arise. The program integrates a significant portion of presently planned non-routine work at O.C. over a nominal five-year period to ensure that tasks associated with issue resolution are properly assessed and effectively scheduled and coordinated. It provides a means for new requirements to be accommodated taking into account schedule and resource constraints, as well as the importance of implementing a new requirement. The purpose of this document is to describe the plan used to implement the program. It describes how the program functions, mechanisms for changing the program and updating it, the interactions and responsibilities of the NRC and licensee staffs under the program, and its resultant assessments and schedules.

The term project as used herein refers to the projected allocation of significant fiscal and manpower resources at O.C. The term issue resolution as used herein refers to the actions necessary to resolve concerns (safety related or otherwise) which have been identified by the NRC or GPUN.

II. SUMM ARY OF PROGRAM DEVELOPMENT The program is based on a list of projects and their projected completion schedules each of which is assigned a priority resulting from an established assessment method. The assessment method involves ranking each project based on its importance relative to public safety (e.g., safe shutdown, radiological release potential), personnel safety, plant availability/capacity factor and economic incentive.

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The scheduling of projects takes into account projections for budgets and site manpower and engineering support requirements for up to five years, on an item-by-item basis covering significant plant projects. The list represents that significant portion of the O.C. work list and commitment list which is regularly modified and updated to meet changing conditions, including new NRC regulatory requirements. The final product of this program is the assessment of projects and the development of associated schedules as discussed below.

III. ASSESSMENT AND SCHEDULING A first step in the development of this program involves the identification and listing of significant open issues and their associated resolutions. Following initial screening and evaluation of identified issues, those whose proposed resolution will require significant planning or resources are defined as proposed projects to be considered in development of the list of projects approved and proposed for approval by GPUN for O.C. over the next 5 years. An assessment of all proposed projects is required to determine their appropriate value/worth and relative priority. Upon completion of the project prioritization and subsequent ranking, the tasks are scheduled based on assigned priority, available resources and schedular constraints. The projects are organized into Categories A, B and C based upon their origin. Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recovery plans. The three categories are briefly described below:

Category A - All projects involving regulatory issues which have resolution dates mandated by NRC rules, orders or license conditions.

Category B - Projects involving issues identified by the NRC and/or GPUN for which commitments have been made to the NRC by GPUN.

The issue resolutions would result in significant a) plant modifications, b) procedure revisions, or c) changes in facility staffing requirements.

Category C - Other major projects, identified by GPUN or other regulatory agencies.

Projects and/or implementation dates in Category A may be modified or deleted only with prior approval of the NRC. Changes to project scope and/or completion dates in Categories B and C require notification to the NRC as described in Section V. Categori es A, B and C, taken together, provide a basis for assessing the overal 1 effects of changes to projects and/or schedules, and a departure point for discussion between the NRC and the licensee regarding such changes, as discussed below.

IV. ISSUE RESOLUTION AND SCHEDULE MODIFICATIONS Project schedules for each planning cycle include required milestones for engineering, procurement and, where appropriate, regulatory review and approval. Inability to meet these milestones may require changes to previous plans and schedules.

Accordingly, an important aspect of GPUN's planning effort is the recognition that projects, project scopes, and scheduled completion dates may need to be modified or deleted at times to reflect changes in regulatory requirements, to accommodate those activities that GPUN finds necessary to improve plant efficiency and reliability, to incorporate the results of investigations into issues, and to take into account delays resulting from events beyond GPUN's controll. The method used by GPUN for changing or deleting projects or scheduled completion dates is established and will be incorporated in the Corporate Procedures.

V. GPUN AND NRC RESPONSIBILITIES The proper functioning of the Long Range Planning Program requires that GPUN apply consistent criteria to the assessment of projects, monitor the progress of work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when a project scope or schedule change is needed. As set forth herein the NRC will treat projects consistently and recognize that, when necessary, ranking, project scope, and/or scheduled completion date changes are based on a comparison of the project scopes and/or completion dates being changed to all projects, and also account for resource constraints.

A. PERIODIC UPDATING GPUN will update Categories A, B and C semi-annually and submit the revised listing of projects and completion schedules to the NRC, beginning six months following NRC approval of this plan. The revised project listing will include the following:

o Summarize progress in completing or implementing projects.

o Identify changes since last update report.

o Summarize the reasons for project scope and/or schedule changes associated with regulatory requirements.

The listing of projects in Categories A, B and C will contain sufficient detail to identify those projects with tasks and/or completion dates keyed to refueling outages. In such cases, a change in outage period (i.e., initiation or duration) shall not be considered a schedule change.

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B. CHANGES TO ISSUE RESOLUTIONS AND/OR SCHEDULES Changes to the project listing may arise from a variety of reasons, such as new projects identified; modifications to the scope of scheduled work; unplanned outages; results of investigations into an issue (e.g., PRA findings); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or GPUN actions.

Where it is necessary to add a new project or to change the schedule for a project, the following general guidance will be utilized to the extent appropriate:

o Assess the priority of the project relative to all existing projects.

o Schedule the new or changed project to avoid rescheduling other projects, if it can be reasonably achieved.

o Select a schedule for the new or changed project which will help in maintaining an optimum integrated program of work.

Addition of activities to Category A requires GPUN to propose appropriate projects and/or completion dates and requires NRC approval of such proposals. Changes to previously established Category A resolutions and/or resolution implementation dates will be proposed only after GPUN has determined that changing Category B and C items will not significantly assist in maintaining Category A without change; or that safety, resource or schedule penalities from rescheduling Category B and C activities significantly outweigh the consequences of a change in a Category A completion date. As with proposals to add Category A activities, proposals to change previously existing Category A activities also requires NRC approval.

GPUN will irform the NRC Project Manager when serious consideration is given to requesting a change in Category A. When GPUN determines that a change in Category A is necessary, it will submit a written request for NRC approval.

Projects in Category B or C may be modified, deleted or rescheduled, or new projects may be added to Category C by GPUN without NRC approval; however, GPUN will inform the NRC Project Manager once a change, deletion, or addition to Category B is necessary. GPUN will provide the NRC with written notification of changes or deletions of Category B projects or completion dates associated with NRC initiated issues at a minimum in each semi-annual update but in any event at least 30 days prior to the scheduled completion date. Such notification will also include the reasons for the change and describe any compensatory actions which GPUN determines to be appropriate.

The change, addition or deletion in Category B will go into effect upon evaluation by GPUN, unless the NRC, in writing, requests further explanation or discussion. NRC requests will be made within 15 days of receipt of GPUN written notification. In this event, discussions will be initiated to promptly develop a project scope and/or schedule which is mutually acceptable to GPUN and the NRC Project Manager while considering overall program impact. The written notification by the NRC will serve to extend the schedule date for the period of time required for such discussion. If a revised project scope and/or schedule is established in these discussions, such project scope and/or schedule will supersede the project scope and/or schedule set forth in Category B. The revised project scope and/or schedule will be incorporated in a revised Category B in the next update submitted to the NRC. If a revised project scope and/or schedule cannot be established in these discussions, GPUN changes to projects scope and/or schedule will be effective unless subsequently modified by NRC Order.

In the event of unplanned delays, delays which become manifest within 30 days of the scheduled completion date or in the event of circumstances beyond GPUN's control, GPUN shall provide timely notification to the NRC Project Manager of the revised project an/or schedule date and incorporate it in a revised Category B in the next update submitted to the NRC.

GPUN will provide notification of changes, deletions, additions or rescheduling of Category C projects to NRC semi-annually. This is for information purposes.

VI. NRC REVIEW As pointed out in Section V.B above, changes to project scope and/or schedules are inevitable. Action required by the NRC is discussed below:

A. GPU NUCLEAR ORIGINATED CHANGES

1. Upon receipt from GPUN of a request for modification of Category A, the NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the request.

2. If the request for a modification of Category A is denied, NRC shall promptly inform GPUN and provide the reasons for denial.

3. NRC consideration of GPUN changes to non-Category A projects and/or schedules is covered by Section V.B.

B. NRC ORIGINATED CHANGES (CATEGORY A)

Is is recognized that formal NRC regulatory actions (i.e., NRC rules, orders, or license conditions) may: (1) impose a new regulatory requirement with a fixed date, or (2) establish a firm date for a previously identified regulatory requirement. In taking any such action, the NRC, to the extent consistent with its overall regulatory responsibilities and, unless public health, safety, or interest require otherwise, will take into account the impact of such action on GPUN's ability to complete effectively the projects in Categories A, B, and C; and in consultation with GPUN, will try to minimize such impact. Although any formal regulatory action (i.e., regulatory rule, order, or license condition) taken by the NRC will be effective in accordance with its terms without inclusion in Category A, the NRC and GPUN recognize the desirability of incorporating such action into Category A, particularly in order to incorporate at the same time any other appropriate changes in the Long Range Planning Program. Accordingly, once such formal regulatory action is taken (or earlier, if practicable), the NRC will provide GPUN a reasonable opportunity to propose overall changes in the Long Range Planning Program which would most effectively accommodate such requirements. Any resulting changes in projects in Category A will be (1) reviewed by the NRC, taking in account the overall objective of the Long Range Planning Program to use available resources effectively, and (2) if acceptable, approved by the NRC, and will thereupon be reflected in a revised Category A listing submitted by GPUN. GPUN will inform the NRC of any resulting changes in Categories B and C in accordance with Section V above.

C. NEW NRC ISSUES (CATEGORY B)

The NRC may, from time to time, identify new regulatory issues which may result in (a) plant modifications, (b) procedure revision or development, or (c) changes in facility staffing requirements. With respect to issues which the NRC requests (1) scheduling information or (2) responses by a certain date, these issues may be included in Category B in accordance with the project priority resulting from GPUN assessment. Projects and/or schedule date commitments resulting from GPUN evaluation will form the basis for discussions between the NRC and GPUN.

As for the case of NRC-originated changes to Category A issues, the NRC will provide GPUN a reasonable opportunity to propose overall changes in the total integrated plan program which would most effectively accommodate such issues. Any resulting changes in the integrated plan program will thereupon be reflected in a revised Category B or C list submitted by GPUN.

D. INSPECTIONS AND AUDITS The Plan and the Long Range Planning Program implementation processes and procedures do not fall within the scope of GPUN's Quality Assurance Program or the requirements of 10CFR50 Appendix B. The existence of the Plan does not change the extent or nature of NRC inspection or audit activities which would be applied in the absence of the Plan. Specifically, the management processes by which resource limits are established and allocated are not subject to detailed audit or inspection. GPUN will provide information as discussed in Section V for review and/or approval by NRC of the basis for the Category A and B project schedules. Implementation of those projects are subject to inspection and audit as required by GPUN QA Program and NRC Regulations.

VII MODIFICATION TO THE PLAN The licensee and the NRC recognize that the Plan itself may require future modifications. Accordingly, all Plan revisions will be submitted for prior NRC approval. The revisions will be made effective on a mutually agreed date upon or subsequent to amendment issuance by the NRC.

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(.AlUGORY' 'It' PROJFC1S SOJRT BY (;AIFGOIkY/(;YCI-F/BA STAT11S AS OF 25APROH 0Ilts N090Eh' DESCRIPTION CL ASSIFICATION 5 4021180 ii NIRR RADJkIVE GASEOUS EFFLUENTS MONITORING 6 402181 RAGE7~N IT 2 FOR T9 ii NRR MOD! IY ~AS SAMPLING SYS FOR NOBI GASES.

A~'RYr5~ Y E 7 TS.

7 402719 MASO JY W9DL MODS--PHASE II It NRR 8 40-2873 DRYWL THINNING - CATHODIC PROTECTION il NRR It4STAýLLCATHODIC T

PROTECTION SYS EM TO R~U~GO~jt DEN IFED RROSIO 9 408077 ENHAVC ENT PROTECTED AREA BARRIER SYS ti NRR ml~~~~ ~ Ayf~rj~'7 ED CA L 4L&ONF SILUMLIX.

10 315302 SEP TOPIC 111-1 12 NRK 11 323391 HFA RELAY 4EPIACEMENTS 1 2R NRR S4iý0 4 v JEhiýEW

I k cIC k I 1 ( V ()J vC I LITS IIN G

':ATFAtiFY 'ti FRkOAUC1S SORI I 8Y (.AlkF(,ORY/(.Y:I.F /14A STAT IS AS OfI "')Al F<UU Oti~s IiA DESCRIFI ION (A1ANSSF If ATION NFUIEF R lEB 84-02.

12 328100 I 2R NkR FM &RD NOZZLE EXTERNAL Ul ;NSF' UT IPECTIONR8F F ~R (4) FW NOZZLES AtpD EINj) C ph? NREG 0619.

F~MOOEIN UL.. MRIE SURFACES 13 321813 0 79-01,ANCY$PR DOLT INSPECTIONS I 2R NRR INSPE TION OF ANCHOR DOLT INSTALLATIONS.

14 3?8160 RCS AUG -. [GSCEBýNSPECT ION 111 R NRR IN FP CT FI rING MELDS.

15) 328195 EFFE~jROF LOCA ON TORUS TO DM BREAKERS I 2R NRk IPDFY VALVE INTERNALLY ANDBEXTERNALLY.

8D1TNU~ L~Q6 L8-0 FOkMANUC 1EHFCW SURVEIL.LA C-S.

16 402i80 RADIF CIIVE GASEOUS EFFLUENTS MONITORING I2R NFRR INSTACL NhWCHECK SOURCE FOR Hi~H RANGE MONITOR. ECORDERS AND RATE METER.

Il7 402181 RAGE9~ UNIT 2 FOR TB 1 2R NRR INSt A I. E HC SOURCE FOR HIGH KANGE MONNIITOCH.

IS 4021811 CDNlkpI ROOM CONSOLIDATED DISPLAY I 2k~ NRR

Uys IFV C R EEK 1Fk 0.1 fc I I IS I INI CATF(.ORY 'B' PROJFCTS SORT H4Y CATFEGORY/CYCL E/BA STATUS AS Of ;"AF'RHO 0 IDS 80~iER DESCRIPTION YCLE CL AXSSIF I CA I ION EOP'S DATA. MiREL 0737 SUPPF i.

19 402857 SW R0 IATAQ NyV IOR SYS UPGRADE 1 2R NRR I IBRIINVOSYJEWITH 20 402-870 C R RECORDERS UPGRADE i2R OýQ RIPt ACI 13 D F CIENT/

Nkk

11 402876 NEW ~jPPO IS AN SUPPORT UPGRADES(79-14) 12R 311 IE NRR duTEIIA.fS 212 40:'877 ISO ERGN CNDNSR PENETRAT IONS MlOD 12R LN5 L AF~ L FT- EAEljSJSAT 23 402879 RPS/E. IIJTRUMENT UPGRADE i2R NRR REPLA 4 PRESSURE SWJTCtES OPERAlIONAL/MAINTENAN E CONERNS 24 328030 CNTRL RM HUMAN FACTORS DFSGN REVIEW 13R NRR REPOATh RýF-UREIf[H t EflAPEL CR F*Nk I.R INCUDING iXR & 9XR.

25 328196 CRD NOZZLE INTERNAL. INSPECTION 1 3R NRR

0 Y SI Ik C RF UiK FR0 JifC 1 11sTII N(G CATEGORY 'I' PROJECTS SORT I'YCAIE(.OkY/CYCLE/BA SIAJIUS AS Of- 25APR88 piis Ro li DESCRIPTION CLASSIFI(CAT(ION 9NJ(

m NUREC-061 9.

26' 328204 I3R NRR RCS AU .1JhFPCION INSPFIT PI Gi~(~ DS.

27 402ACD CR [C ORDERS 13R NRR 0 E SUPP i.

28 402YYY i3R NRR RMVDENS. COMP. FROM RX H20 LVL RUC.

29 402808 CONVRT COMPUTER RM TO GSSI/EMER DIR OFFC 1 3R NRk CPR PERMANENTLY REMOV IGFARCOMPUTER FROM FUPIIE CNRTSACF$IhNTýG jl*

LSXI IH7CFE. EIRIES SECRITY PROOIN 30 402859 ESW F OW ~CAT ION (CONTROL ROOM) 1 3k NRR INTAL JNI

ýgFLOW O S ANEL

ý VNR

&GO~FARF JýAjplS. TO CR.

31 402872 TOI O J05PLE L INE ISOLATION i3R NRR ADD A RELAY 9LOCAL WIRING IN PANEL iiF.

IN ýLL CABLE FRO" CR TO 02 ANALYZER 32 402879 RPS/ý 6 INSTRUMENT UPGtRADE I3R NRR R[PLA ? 29 PI EWL TCgPES 0EAfTONAL/MANlYNANCE C NC(IRNS.

O-YS I I. (R II k PR 0 1F S T IN U, CAJIGOkY 'p rRO IEC1S

-SORT lHY (.AJF(.oRY/CYCtEEfA STATUS AS OF 2ýARl*HH I)Fis 14A DESCR IV] TON NUMIIFWR YEA S CI ASSIF It'Al ION 33 40211(18 REV VA~fULE #2 i 3R INkTALh CAPSULE #2 IN 'R VESSEL. NRk 34 QH(205 SQUG SUPPORT & PARTICIPATION - ORROG 87-90 PARTI tOAttbN' NthithIC QULIAFICATION NRR OFFYI.JTY.G T RQf FR U 'F IE!$I1WQUA LI CAT ON. URSOVEb'S'A"FElY ISE 35 328092 VENDOR DOCUMENT CONTROL PROGRAM 87/89 NRR F

IIY S I I I- CI I K V ROJ E CT I I S I Nt.

ilA II ORY 'C: FR() EcTS SORT B4Y CAlf(.ORY/CYC1[/IbA SI AllS AS OIf 25Al*H8 (his BIA DESCRIPI ION cyck.V Cl ASSIF It AT TON NlIM1 F R YFA .

36 402138 ADDIN PN FUEL SIORAC.C RACKS il MRC~'

INCl; j~ CAPACITY BY INSTALLATIO EfRACK.

3e' 402792 CHLO14~NCTON UPGRADE il REPLAC~E' EXT 3TI 4G CphORINATION SYSTEM WITH 10Z SOD Lii HYPOCHLORITE SYS TO METNJEPA iTS 301 409522 MAC FACI~LITY REFURBISHMENT 11 ORRC

~9 VrET~N~TMPUR ACRFAJh ITY.

NML. CEMITMN CO Y UN DUXAR 39 402ACE REPI.jrýER TO & OLD MACHINE SHOP ROOF NRC T

r% C HVl~~ URBJN YUILDING 40 402763 WATER HyE l TRY MONITORING~ SYSTEM 12 MRC 0 O~LPV 0 COD!JVTY FOR FWDISCAR~E . OF~SNLNG AM& STA 41 402836 DILUIO1N PUMP HOUSE REPAIRS & NODS 12 MRC INSPIt & REPAIR VF CONCRETE.

REPLACF TRASH CART AND RAILS.

4:' 323540 LP 1lyI4INE INSPECTION NRC I MNPU~ N ~~ R O~~Ot1CAI¶I.,

0 Y sI I R C k I IK FRO0 IF C1 1 ISTIIN G CA If (J(liRY 'C. F~f) If CIi S SORT 14Y C.All .OkY/(1YII I /'ItA ST AIU[S AS OF ',`AFId4H (ills EIA DESCRIPTION f I As.s IF I UA IJIUN NUIIlif R SANDBLAST UT INSP & RLINSTALL ROTOR.

~PROVEMENT I ?R NFRR 43 32816l RCS JTRES FIERFN pS IMPROVEMENT ON SELF('TFD H2W9ER Er IJJRY IMPLEMENTATION 44 4021840 I 2R N~k INWTA S(iP-LyLINED CNTROLS.

Tr -I AND rP noN" tokS.

45, 32..3451 Lf' TV VINE INSPECTION UAo & *]H*) 13k MRC u:JNPL.I 1 ~EClSP~~ ION OF TM SAN[---ANe tI TALL ROT OR RCS JTR[SSýMIPROVEMUNT i 3R NRR 46 32HAIII PERF G~I STRtS-S IPfPROVEMFNI ON SELECTED STAINLESS STEEL F*IP'ING WEI DS IN RCS SYS.

4? 40:1636 WIDE. OANGE NEUTRON MONITORING 1 3R NRR D I REG CLINE 1.97 ITEM NRC COMMITIMENI UNDER REVISION.

411 402816 [SW I ~NG UPGRADE I 3R MRC REPI C~RFPAIR DTROATED PORlIONS OFI ESW P1 FI N. A TI NEiAIKE STRUCTURE.

49 4028414 UNDI-t VESSEL CAR4LING I AR MRC 5

~~ANylby~l ~tll ,OAI?'AI

0 Y ST F R C R V V K P ROJE C T L I S I N NGI CATUGORY 'C' PfRO.IECIS SORT 14Y CATE(,ORY/(CYCLF/14A STATUS AS 01' 2`AF'kfl88 IObS 14A DESCRIPTION (I ASSIF ICA] ION r41IPmiER DISCONNECT - -MORED CABLE.

HP TYVIINE INSPECTION 14R m?{FC 50 323411 WMP TEpIjT I&.INSPECTION 51 328049 D.C. LOCA APPENDIX K RE-EVALUATION 87 NRR RO P~ff~ ff0"gk FpR OC 328146 PROBABILISTIC RISK ANALYSIS UPDATE 87-89 NRR 52

.LAN$ kTNCE 1979.

87-90 NRR 53 40?011 PkCA SIMULATOR OC REyAD DESI N FABR ICATE I VSTALL A SIMULATOR S RINA.

~

AUi SON ot U ROL k" FUNCTIONS u.

54 328182 AS-BUILT DRAWING PROGRAM 87-91 XýAfflhl RE IfNl REFLECT AS BUILT/

328226 SQUG PROGRAM IMPLEMENTATION 87-91 NRR 55 HSTAtM1H*MSIAlt'QbA0tFICATION FOR YSTER CREEK.

87/88 TOE 56 328183 CANlE MANAGEMENT PROGRAM

ýAM" ANA C

(" F' BASED

0 Y NI iR C k F LK fRO'1E cII IIs IIN G CAIFGf kl *C PRO JECIS SOkd tlY (.ATfrGORY /CYCL F/14A SIAJOS AS OF 25AFR98 OHS4 PA DESCRIPTIJON cycki/ (A ASS IF I! Al ION NiIMrIIF R

'- 328'231 DC MATERIAL CONDITION EVALUATION UPDATE 87/88 MRC UVAlg 'fAl~;WU ION STUDY 10 58 328215 DECAY HEAT REMOVAL RELIABILITY (115) 89 NRR 59 318216 STATION BLACKOUT 89 NRR