ML18100A687
| ML18100A687 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 11/03/1993 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N93157, NUDOCS 9311040224 | |
| Download: ML18100A687 (7) | |
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Public Service Electric and Gas Company Stanley LaBruna
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Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1700 Vice President - Nuclear Engineering NOV 0.3 1993 NLR-N93157 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Gentlemen:
INTEGRATED SCHEDULING PROGRAM FOR MAJOR MODIFICATIONS SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 In a letter dated February 26, 1993, public Service Electric and Gas Company (PSE&G) forwarded a formal request for NRC staff review of our proposed Integrated Scheduling Program {ISP) for major modifications at the Salem and Hope Creek Stations.
Our Program was based on the NRC's Final Policy Statement on Integrated Schedules (57FR43886).
The Staff reviewed our request.
Based on that review and a meeting held on May 11, 1993, the Staff forwarded their comments in a letter dated July 23, 1993.
PSE&G conducted a telecon with the J. Stone, NRR Project Manager for Salem, on September 21, 1993, to clarify some of the Staff's comments.
Our response to the Staff's comments is attached.
Should you have any questions on this transmittal, please contact us.
Attachment (1) 040015
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Sincerely, fPDl I I
Doqument Control Desk 2
NLR-N93157 c
Mr. T. T. Martin, Administrator - Region I
- u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. J. c. Stone, Licensing Project Manager -
Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. S. Dembek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. Marschall (S09)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 NOVO 3 1993
ATTACHMENT
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NRC COMMENT Page 1 of the Overview, Scope, states that the items included in the ISP will have a cost of greater than
$50,000.
In the May 11, 1993, meeting PSE&G agreed to reconsider this limit to see if it would be appropriate to increase the dollar value of the threshold.
PSE&G RESPONSE PSE&G initially selected the $50,000 value, because that is the threshold used in our existing Nuclear Department Resource Allocation Program (NDRAP).
NDRAP is a site-wide process to assure that Nuclear Department resources are only allocated to work items that provide appropriate value to PSE&G.
Using the same threshold value would simplify interactions between NDRAP and the ISP.
We have reconsidered the threshold value and have decided to raise it to $1,000,000.
This will reduce the number of items tracked and focus attention of those projects that absorb.significant resources.
- 2.
NRC COMMENT Page 1 of the overview, Item 2, states that Programatic changes that are made after program approval will be implemented prior to NRC review.
The Staff's position is that Programatic changes that..,are made after program approval should be submitted to the NRC.under the 90-day negative consent provisions of the policy statement.
Implementation would follow the 90-day period.
PSE&G RESPONSE PSE&G wants to limit Programatic changes that require NRC pre-approval-to those that are "significant" changes.
We attempted to establish a significance threshold by comparing proposed changes to the criteria specified in the NRC's Final Policy Statement.
Those that met the criteria could be implemented prior to NRC review.
However, since the policy statement is written in broad terms, this may not be a good barometer of significance.
PSE&G proposes to submit changes that effect some significant aspect of the Program to the NRC for their review under the 90-day negative consent provision (e.g.,
significant change in the prioritization methodology).
Changes that do not have a significant impact 1 of 5
on the existing Program will be implemented and described in the next Program update letter (e.g., changes that are editorial, changes that only alter the internal review process).
3.
NRC COMMENT
- 4.
Page 2 of the Overview, Item 5, states that completion date changes to N2 categorized items do not require NRC pre-approval.
The Staff disagrees with this position.
Proposed changes to N2 categorized items are to be submitted to the NRC along wtth the justification for the change.
The NRC then has 90 days*to r~view the proposed change (90-day negative consent).*
PSE&G RESPONSE one of the major benefits of *the ISP is the ability to change existing items when new, more safety significant items are identified.
NRC confidence of proper Program operation is based on prior review and acceptance of our prioritization methodology used to rank projects.
Submitting each change individually removes this benefit and restores t.he existing system.
PSE&G proposes to make changes to N2 items as necessary based on item prioritiz~tion ranking.
Changes will be identified and justified in the next Program update submitted to the NRC.
The 90-day negative consent of all identified changes will begin upon NRC receipt of the Program update.
NRC COMMENT Page 2 of the Overview, Item 5, states that the appropriate Project Manager will be verbally notified when a change is necessary before the next semi-annual update.
All other changes will be addressed exclusively through the semi-annual update.
The Staff's position is that all changes and the justification to items coded N2 must be submitted in writing at the time the need is identified.
The 90-day negative consent period starts at that time.
This same comment applies to page 15 of the Policy Statement, Continued Licensing and Regulator Interface.
PSE&G RESPONSE Another major benefit of the ISP is the ability to minimize the number of transmittals to the NRC by consolidating many of these items into the ISP periodic updates.
Submitting each change request individually at the time of need removes this benefit and restores the existing system.
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PSE&G proposes to handle most changes through the periodic Program updates.
These updates will identify all changes from the last update and include the justification for each change.
The only exceptions are for those due date changes that occur before the next update, and those changes that PSE&G determines are significant enough, or sensitive enough to require individual attention and notification.
The purpose of the verbal notification to the appropriate NRR Project Manager was to keep this individual abreast of the most current ISP status.
The 90-day negative consent for changes begins upon NRC receipt of the docketed Program update, not upon verbal notification to the NRR Project Manager.
- 5.
NRC COMMENT Page 3 of the overview, Item. 6; a semi-annual update of the schedules may be t66 frequent.
in the May 11, 1993 meeting, PSE&G agreed to re-examine this update frequency.
PSE&G RESPONSE PSE&G has re-examined the update frequency and believes that the proposed semi-annual frequency is appropriate.
Extending the frequency to something longer-will result in a larger number of changes between updates, and reduce the effectiveness of the periodic update as a tool to handle
- most item changes.
Also, since the ISP may experience some initial "bugs" upon implementation, more frequent initial updates are prudent.
PSE&G proposes to begin with a semi-annual update frequency and evaluate after a period of time whether this rate should continue.
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- NRC COMMENT Page 3 of the Overview, Item 7, discusses the short term response to NRC items.
The final corrective actions and schedule should be forwarded to the NRC as soon as it is finalized and not wait for the next schedule update.
PSE&G RESPONSE Refer to PSE&G response to NRC comment 4.
We reiterate that a major benefit of the Program is to reduce the number of NRC transmittals and address as many items as possible through the periodic updates.
PSE&G intends to respond to short-term NRC response items (e.g., Notices of Violations, LERs) within the designated time frame (normally 30 days).
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The response will address the results of our issue/event assessment.
Corrective actions that do not involve a plant modification or major programatic change (e.g., revise a procedure, address an item in an existing training program) will be discussed in the initial submittal.
Corrective actions involving significant changes require further evaluation to determine scope and schedule.
Those corrective actions determined to be <$1,000,000, will be
,forwarded to the NRC upon completion of the Project Evaluation Proposal (PEP).
For corrective actions in excess of $1,000,ooo, scope and schedule for completion will be included in the next periodic update after PEP completion.
7.
NRC COMMENT Page 8 of the Policy Statement, Regulator Interface, discusses responses to regulatory agencies.
Included is a discussion of th~ 90-day negative consent period but it does not exempt items coded as Nl from the 90-day negative consent period.
This statement should be revised.
PSE&G RESPONSE PSE&G has revised the Policy Statement to clearly indicate that the 90-day negative consent does not apply to Nl categorized items.
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- NRC COMMENT Environmental items that fall under the jurisdiction of the NRC should be coded as N2, unless they are required under the regulations, then they should be coded Nl.
PSE&G RESPONSE PSE&G agrees to classify all environmental items under NRC jurisdiction as Nl or N2.
9.
NRC COMMENT There have been *occasional past lapses completing regulatory required work as committed to the NRC.
The most notable was the failure of the Salem 2 main turbine in November 1991.
It is not apparent in the, ISP description, how the "Regulatory Required~' designator will assure proper evaluation and implementation of commitments.
PSE&G should provide some additional detail to clarify th~ use of "Regulatory Required."
PSE&G RESPONSE Regulatory related items that enter the ISP are annotated with the "Regulatory Related" designator and receive an*
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adder to the task score.
The purpose of this adder is to expedite completion of the Project Evaluation Package (PEP).
The PEP serves as an initial scoping mechanism providing an early determination of project workscope, feasibility, cost, schedule, resource impact, and economic benefit.
The ISP, through the Integrated Long Range Plan, supports long-term planning, resource* management and workscope control.
Our Action Tracking System (ATS) is used to track NRC commitments.
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