ML18101A678

Discusses Util Cost Beneficial Licensing Actions Process,In Response to NRC Interest Expressed During Recent Visit W/ Pse&G Board of Directors

ML18101A678
Person / Time
Site:	Salem, Hope Creek
Issue date:	04/19/1995
From:	Eliason L Public Service Enterprise Group
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
References
LR-N95062, NUDOCS 9505020331
Download: ML18101A678 (7)

Text

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Public Service Electric and Gas Company Leon R. Eliason Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1100 Chief Nuclear Officer & President APR 19 1995 Nuclear Business Unit LR-N95062

u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Attention:

Mr. William T. Russell - Director Off ice of Nuclear Reactor Regulation

Dear Mr. Russell:

• COST BENEFICIAL LICENSING ACTIONS HOPE CREEK AND SALEM GENERATING STATIONS Recently, during a visit with the PSE&G Board of Directors, an interest was expressed in the efforts being taken towards reduction of low value work from a regulatory perspective.

This memo, addressing our Cost Beneficial Licensing Action (CBLA) process, is in response to your interest.

PSE&G has been aggressively pursuing CBLA's with the NRC since the programs inception in 1993.

PSE&G has developed a program to identify regulatory requirements that have a high cost with a low safety significance.

Once a CBLA candidate is identified, a justification for relief is developed in accordance with appropriate regulatory requirements.

Representatives from PSE&G met with the NRC staff on November 12, 1993 to brief the NRC staff on our program for identification of CBLAs and schedule for submission of initial requests, and to align with the NRC staff on the most effective means for processing CBLAs.

We discussed our process and the NRC staff provided feedback, which we incorporated into our process, to most effectively utilize our resources and the NRC staff's resources.

PSE&G's CBLA process includes the following:

Identifying specific regulatory changes that would reduce cost without compromising safety by reviewing programs (value added versus resources expended), soliciting input from plant personnel to identify distractions or work they feel has low value added (i.e., distractions to operators),

referring to the improved Standard Technical Specifications to identify changes that the NRC has approved from which we could benefit, reviewing submittals made by other utilities and the Federal Register, and maintaining awareness of NRC regulatory response group initiatives and NEI initiatives.

Document Control Desk LR-N95062 2

APR 19 1995 Our process focuses on plant specific items, while any large scope, generic items are left for NEI to process with the NRC.

Researching the identified items to determine the feasibility of pursuing approval under the CBLA program:

identify driving requirement/commitment and the reason for the requirement/commitment, determine regulatory significance (ease of approval), formulate estimated cost savings, determine safety significance.

Prioritizing the CBLAs based on the safety significance, estimated cost savings, regulatory significance, and implementation time; maintaining a mix of changes that can be processed fairly quickly and those that require more time; periodic meetings held with plant management to align on priority.

Categorizing the CBLAs based on the required relief process (i.e., 50.59 approval, NRC approval through a letter or requested change to the license, or an exemption).

Developing the justification for the specific CBLA by demonstrating that there is a minimal safety impact or there are alternative means of addressing the issue.

Ongoing communication with the NRC as to the progress in developing and implementing the program.

Keeping abreast of initiatives developed by peer groups and NEI.

In 1994 alone, PSE&G developed 52 licensing actions, for either internal review and processing or submittal to the NRC, that we characterized as CBLAs, 38.of which were Technical Specification change requests.

While our definition of CBLA includes the

$100,000 threshold criteria defined by the NRC, it also includes those changes which provide either operating flexibility, reduced outage duration, or a reduction in unnecessary risk of plant shutdowns' (i.e., without commensurate safety benefits).

Our definition of CBLA also includes those changes approved on a generic bases.

These latter items are captured because the benefits are considered significant, while the actual cost savings are difficult to quantify.

In addition, many license changes that we categorized as CBLAs can be shown to increase safety and therefore are not always identified as CBLAs to the NRC on the docket.

95-4933

Document Control Desk LR-N95062 3

APR 19 1995 Our progress to date is summarized in the Attachments to this letter. indicates the number of PSE&G CBLA's approved in 1993 and 1994, and the associated cost savings over the life of the plants.

In 1993, 7 PSE&G CBLA's were approved for the Salem Generating Stations (SGS), yielding a cost savings of approximately $25,000,000 over the life of the SGS.

Also in 1993, 7 PSE&G CBLA's were approved for Hope Creek Generating station (HCGS), yielding approximately $27,000,000 over the life of the HCGS.

In 1994, an additional 28 PSE&G CBLA's were approved:

15 PSE&G CBLA's were approved for SGS yielding cost savings of approximately $26,000,000 over the life of the SGS, 12 PSE&G CBLA's were approved for HCGS yielding cost savings of approximately $31,000,000 over the life of the HCGS, and 1 PSE&G CBLA was approved that was common to all Stations yielding cost savings of approximately $2,000,000 over the life of the Stations.

As the figures show, we have been aggressively pursuing CBLA's with the NRC and have seen significant cost benefits.

Our cost estimates are based on rules of thumb common throughout the industry.

For example, the cost of an engineers time is $50/hour.

We currently have approximately 150 additional items identified as possible CBLAs, approximately 40 of which are currently under development.

Our CBLA program continues to aggressively pursue regulatory relief where it can be shown that safety is not compromised.

Our success can be attributed, in part to, the support of our Nuclear Reactor Regulation Project Managers.

We have very frequent communications with our Projects Managers specifically concerning the CBLA program~

We have established and maintain a "Top Ten" list with each Project Manager that ranks the amendment requests in the order in which PSE&G would like them to be reviewed and approved.

These "Top Ten" lists are shown in.

The Project Managers have been very supportive of our schedule requests and have assisted us in streamlining the process.

This communication has proven very successful.

I appreciate the support your staff has provided in eliminating low value work.

We will continue to focus on plant specific changes as opposed to large scope generic changes.

However, we will continue to support generic submittals with NEI.

If you have any questions or comments regarding our CBLA program, please feel free to contact our Manager - Licensing and Regulation at (609)339-1229.

Sincerely, Attachments (1)

Document Control Desk LR-N95062 c

'Mr. J. Ferland 4

Chairman o.f the Board * & CEO Newark, 4B Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Mr. T. T. Martin, Administrator - Region I U. s. Nuclear Regulatory Commission*

475 Allendale Road King of Prussia, PA 19406 APR 1 9 1995 Mr. J. Taylor, Executive Director of Operations U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. L. N. Olshan, Licensing Project Manager -

Salem U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. D. Moran, Licensing Project Manager -

HC

u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. s. Marschall (S09)

USNRC Senior Resident Inspector Mr. R. Summers (S09)

USNRC Senior Resident Inspector

PSE&G COST BENEFICIAL LICENSING ACTION PROGRAM CBLA STATISTICS 1993 Approvals:

station

1. Approved

$ saved (over life of plants)

Salem 7

-$25,000,000 Hope Creek 7

-$27,000,000 I Total I

14 I

-$s2,ooo,ooo I

1994 Approvals:

station

1. Approved

$ saved (over life of plants)

Salem 15

-$26,000,000 Hope Creek 12

-$31,000,000 Common 1

-$2,000,000 Total 28

-$59,000,000

PSE&G COST BENEFICIAL LICENSING ACTION PROGRAM TOP TEN LISTS Salem

1.

Individual Rod Position Indication

2.

ILRT One Time Exemption

3.

Pressure/Vacuum Relief Valve (VC4 & 6)

4.

Battery Cell Voltage

5.

Reactor Trip Switch and Reactor Trip Breaker

6.

Turbine Driven Aux Feed Pump steam Pressure

7.

Add Type C Leakrate Testing Exemption Note to BF-22's

8.

Extend Surveillance Frequency of Pressurizer Heaters

9.

RCS Flow Requirements

10.

Reduction in QA Audits Hope creek

1.

Eliminate Appendix J Testing for Valves in Lines that Penetrate the Torus and Terminate Below the Water Line

2.

EOG AOT Extensions

3.

SACS/SSWS AOT Extensions

4.

EOG On-line Maintenance

5.

EOG SR Elimination:

Inspect IAW Vendor Recommendation

6.

LPCI Type c Test Elimination

7.

Elimination of Selected Response Time Testing

8.

STI/AOT Extensions for Selected Instrumentation

9.

Establish AOT for HPCI Inop Coincident with LPCI or CS Inop

10.

Relocation of Turbine Overspeed Protection System

HE:CEiVT.D -REGION 1

• 95 APR 25 -8 :35