ML18144A134
| ML18144A134 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/13/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Rubenstein L Office of Nuclear Reactor Regulation |
| References | |
| 85-836, NUDOCS 8512300319 | |
| Download: ML18144A134 (15) | |
Text
e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STBWART VICE PRESIDENT NUCLEAR OPERATIONS December 13, 1985 Mr. Harold R. Denton, Director Serial No.85-836 Office of Nuclear Reactor Regulation E&C/RWC/acm Attn: Mr. Lester S. Rubenstein, Director Docket Nos. 50-280 PWR Project Directorate #2 50-281 Division of PWR Licensing-A License Nos. DPR-32 U.S. Nuclear Regulatory Commission DPR-37 Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT NOS. 1 AND 2 REQUEST FOR LICENSE AMENDMENT - INTEGRATED IMPLEMENTATION SCHEDULE In my letter dated July 5, 1985 (Serial No.85-362), Virginia Electric and Power Company (the Company) indicated that we would be submitting an Integrated Implementation Schedule (IIS) license amendment in December 1985. Pursuant to 10 CFR50. 90, we hereby request a revision to the Operating Licenses, DPR-32 and DPR-37, for the Surry Power Station, Unit Nos. 1 and 2. The proposed revision adds a paragraph to each station's license (see Enclosures 1 and 2) that requires the implementation of the Company's Integrated Implementation Schedule Plan (the Plan).
The Plan is attached as Enclosure 3. It provides a summary description of the mechanisms for changing and updating the implementation schedules developed under the Company's Integrated Implementation Schedule Program, the responsibilities of the NRC and our staffs with respect to the Plan, and the mechanisms for modifying the requirements of the Plan.
The implementation schedules, which are not a part of the Plan, will be submitted at a later date. Development and modification of these schedules will be accomplished in conjunction with the NRC Project Manager as described in the Plan.
The proposed change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and by the Safety Evaluation and Control Staff. As indicated in the enclosed Safety Evaluation (Enclosure 4), it has been determined that this request does not pose any unreviewed safety question as defined in 10 CFR 50.59 nor does it pose a significant hazards consideration as defined in 10 CFR 50.92.
We have evaluated this request in accordance with the criteria in 10 CFR 170.12. A check in the amount of $150 is enclosed as an application fee.
In order to obtain the initial NRC response on our submittal in preparation for discussion of our proposed implementation schedules, we
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e e VrnoINIA ELEcTrt1c AND PowER CoMPANY To Mr. Harold R. Denton would like to meet with the appropriate NRC staff in January 1986. We will be contacting the NRC Surry Project Manager to arrange a mutually acceptable time. If you have any questions or require additional information to support this effort, please contact us.
Very truly yours, UL~
W. L. Stewart
Enclosures:
- 1. Proposed License Amendment Change to DPR-32
- 2. Proposed License Amendment Change to DPR-37
- 3. Integrated Implementation Schedule Plan
- 4. Safety Evaluation
- 5. Application Fee cc: Dr. J. Nelson Grace Regional Administrator NRC Region II Mr. Donald J. Burke NRC Resident Inspector Surry Power Station Mr. Charles Price Department of Health 109 Governor Street Richmond, Virginia 23219 Mr. Terence L. Chan NRC Surry Project Manager PWR Project Directorate #2 Division of PWR Licensing-A
COMMONWEALTH OF VIRGINIA)
)
CITY OF RICHMOND )
The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today by W. L. Stewart who is Vice President -
Nuclear Operations, . of Virginia Electric and Power Company. He
- is duly authorized to execute
- and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this \ 3 day of De.Q...e.,:m,\ie_'"' , 19 ~-~---
My Commission expires: ,t~r-1..'.) Q..'""'-'\ \D , 19 ~C\
Notary Pul5lic *
(SEAL)
S/001
PROPOSED LICENSE AMENDMENT CHANGE TO DPR-32 I
e e I. Secondary Water Chemistry Monitoring Program The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:
- 1. Identification of a sampling schedule for the critical parameters and control points for these parameters;
- 2. Identification of the procedures used to quantify parameters that are critical to control points;
- 3. Identification of process sampling points;
- 4. Procedure for the recording and management of data;
- 5. Procedures defining corrective actions for off control point chemistry conditions; and
- 6. A procedure for identifying the authority responsible for the interpretation of the data, and the sequence and timing of administrative events required to initiate corrective action.
J. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Nuclear Security Personnel Training and Qualifications Program, including amendments and changes made pursuant to 10 CFR 50. 54 (p). The approved Nuclear Security Personnel Training and Qualifications Program consists of a document withheld from public disclosure pursuant to 10 CFR 2.790(d) identified as "Surry Power Station Nuclear Security Personnel Training and Qualifications Program" dated September 15, 1980. The Nuclear Security Personnel Training and Qualifications Program shall be fully implemented in accordance with 10 CFR 73.55(b)(4), within 60 days of this approval by the Commission. All security personnel shall be qualified within two years of this approval.
- 4. The Integrated Implementation Schedule Plan for Surry Power Station Units 1 and 2 (the Plan) submitted on December 13, 1985 , is approved.
a) The Plan shall be followed by the licensee from and after the effective date of this amendment.
b) The provisions of this paragraph shall be effective for a period of three years following the date of issuance by the NRC and may be renewed upon application by the licensee.
- 5. This license is effective as of the date of issuance, and shall expire at midnight June 25, 2008.
FOR THE ATOMIC ENERGY COMMISSION Original signed by A. Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Enclosure Appendix A -
Technical Specifications Date of Issuance: May 25, 1972 Surry - Unit 1
e e PROPOSED LICENSE AMENDMENT CHANGE TO DPR-37
e I. Secondary Water Chemistry Monitoring Program The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:
- 1. Identification of a sampling schedule for the critical parameters and control points for these parameters;
- 2. Identification of the procedures used to quantify parameters that are critical to control points;
- 3. Identification of process sampling points;
- 4. Procedure for the recording and management of data;
- 5. Procedures defining corrective actions for off control point chemistry conditions; and
- 6. A procedure for identifying the authority responsible for the interpretation of the data, and the sequence and timing of administrative events required to initiate corrective action.
J. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Nuclear Security Personnel Training and Qualifications Program, including amendments and changes made pursuant to 10 CFR 50.54(p). The approved Nuclear Security Personnel Training and Qualifications Program consists of a document withheld from public disclosure pursuant to 10 CFR 2.790(d) identified as "Surry Power Station Nuclear Security Personnel Training and Qualifications Program" dated September 15, 1980. The Nuclear Security Personnel Training and Qualifications Program shall be fully implemented in accordance with 10 CFR 73.55(b)(4), within 60 days of this approval by the Commission. All security personnel shall be qualified within two years of this approval.
- 4. The Integrated Implementation Schedule Plan for Surry Power Station Units 1 and 2 (the Plan) submitted on December 13, 1985 , is approved.
a) The Plan shall be followed by the licensee from and after the effective date of this amendment.
b) The provisions of this paragraph shall be effective for a period of three years following the date of issuance by the NRC and may be renewed upon application by the licensee.
r
- 5. This license is effective as of the date of issuance, and shall expire at midnight June 25, 2008.
FOR THE ATOMIC ENERGY COMMISSION Original signed by A. Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Enclosure Appendix A -
Technical Specifications Date of Issuance: January 29, 1973 Surry - Unit 2
INTEGRATED IMPLEMENTATION SCHEDULE PLAN e
Virgini~ Electric and Power Company Integrated Implementation Schedule Plan for the Surry Power Station, Units 1 and 2 I. INTRODUCTION This document describes the Integrated Implementation Schedule Plan (the Plan) to be used to implement Virginia Electric and Power Company's (the Company) Integrated Implementation Schedule Program (the Program) for the Surry Power Station Units 1 and 2 (the Station). The Plan provides a summary description of the Program, the mechanism for changing and/or updating implementation schedules, the interactions of NRC and Company staffs under the Plan, and the mechanisms for changing the Plan. The Program enables the Company to effectively manage implementation of modifications to the Station that have.been required or proposed by the NRC, as well as other measures to enhance the safety and performance of the Station identified by the Company. The Program objectives are to:
- Ensure conformance to regulatory requirements;
- Provide sufficient lead times for modifications;
- Minimize changes for operators;
- Assure that training requirements are fulfilled;
- Manage financial and human resources effectively; and
- Specify the framework for making changes to developed implementation schedules.
The Plan recognizes that fiscal and manpower resources are finite and that the interest of plant safety and performance are best served by careful planning for the use of these resources. The Plan integrates the presently planned work at the Station over a nominal three year period to ensure that work items are effectively scheduled and coordinated. It also provides a means for new work items to be accommodated, taking into account schedule and resource constraints. The requirements of the Plan are fulfilled by the existence and maintenance of implementation schedules in accordance with the Plan. The internal schedules and the Company's internal planning and scheduling processes described in the Program which are used to generate schedules are not under the requirements of the license provision endorsing the Plan.
II. PROGRAM DESCRIPTION
SUMMARY
The Program provides for a compilation and assessment of the work items currently in progress or planned. The compilation and assessment takes into account projections for budgets, manpower, and engineering support requirements for three years. It represents a comprehensive picture of Station work which is regularly updated to reflect changing conditions, including new NRC regulatory requirements and issues. A primary product of the Program is the development of implementation schedules as discussed below.
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III. IMPLEMENTATION SCHEDULES Implementation schedules are developed to reflect major* work items currently in progress or planned. The development process includes the schedules, estimates of resource requirements, establishment of relative priorities and the methodology of integration. The major work items are organized into two implementation schedules:
Schedule A - Items which have implementation dates mandated by NRC regulations, orders or license conditions.
Schedule B - Items of either a generic or plant specific nature identified by the NRC which have implementation dates committed to by the Company and which would result in either a) plant modifications, b) procedure revisions, or c) changes in facility staffing requirements; and items identified by other agencies or the Company, in anticipation of requirements or for enhancement of Station reliability or efficiency.
Where appropriate, implementation schedules will identify completion dates keyed to refueling outages.
/
IV. IMPLEMENTATION SCHEDULE CHANGES An important aspect of the Plan is the recognition that Schedule A and
.Schedule B may need to be modified at times. Modifications to implementation schedules may arise from a variety of reasons, such as new work items; modification in the scope* of scheduled work; problems in delivery, procurement, etc.; changes in NRC rules and regulations; or other NRC or Company actions. It is important that the procedure used by the Company for changing the schedules be documented. The NRC must play a role in the oversight of the schedules; accordingly, it is important that the NRC s role, and the interaction between the NRC and the Company be 1
clearly defined, as discussed below. The Company will monitor the progress of the work undertaken, manage its activities to maintain the schedule and act promptly to take necessary actions when a schedule change is needed.
When it is necessary to add a new work item or to modify the implemen-tation schedule for an existing item, the following general guidance will be utilized to the extent appropriate:
- Avoid where practical, rescheduling of items with implementation dates mandated by NRC regulations, orders, and license conditions.
- Consider the relative priority of work items.
- Select a schedule for the new or changed item which will help in maintaining an optimum integrated program of work.
- Minimize rescheduling of items currently scheduled.
In cases where a completion date is keyed to a refueling outage, a change in the outage period shall not be considered a schedule change.
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A. Changes to Schedule A
- 1. Changes to Schedule A are categorized as follows:
- a. Changes to existing implementation schedules
- b. Addition of new items
- c. Addition of items previously included on Schedule B
- 2. Changes Initiated by the Company The Company may request NRC approval of changes to Schedule A in accordance with applicable NRC regulations. Such requests will be considered in a timely fashion by the NRC. If the request for a modification of Schedule A is denied, the NRC shall promptly inform the Company and provide the reasons for denial.
- 3. NRC Action Resulting in Changes The NRC may initiate action which will change Schedule A by issuing or revising applicable regulations, orders, or license*
conditions. Before taking such action, the NRC, to the extent consistent with its overall regulatory responsibilities, will take into account the impact of such action on the Company's ability to effectively complete the items on Schedule A and B, and in consultation with the Company, will try to minimize such impact.
The Company will have the opportunity to present alternatives which effectively accommodate the NRC's proposed actions.
B. Changes to Schedule B
- 1. Changes to Schedule Bare categorized as follows:
- a. Changes to existing implementation schedules
- b. Addition of new items
- 2. Changes Initiated by the Company The Company may make changes to Schedule B items as circumstances require. When proposing planned delays to implementation schedules established by a Company commitment for work items identified by the NRC, the following procedure will apply:
- a. The Company will notify the NRC in writing at least 30 days or as early as practical in advance of the implementation date affected and include with the written notification, the reasons for the change and any compensatory actions the Company plans to institute.
- b. The revised schedule proposed by the Company will go into effect unless, within 15 days of receipt of the notification, the NRC requests, in writing, further explanation or discussion concerning the change.
- 77-LH-20238-3
e e
- c. If the NRC makes such a request, discussion will be initiated to promptly develop a schedule which is mutually acceptable to the Company and the NRC Project Manager while considering overall program impact. During the course of the discussions the Schedule B dates in question are suspended pending the outcome of the discussion.
- d. If a new schedule is established during these discussions, it
- will be incorporated into the subsequent semiannual submittal to the NRC.
- e. If a new schedule cannot be established during these discussions, the schedule changes originally proposed by the Company will go into effect unless subsequently modified by NRC order.
In the event of unplanned delays or circumstances beyond the Company's control, the Company shall promptly notify the NRC Project Manager of the new date and incorporate it in a revised Schedule Bin the subsequent semiannual submittal to the NRC.
- 3. Changes initiated by the N~C The NRC may identify new regulatory issues by means other than regulations, orders, or license conditions which may result in a) plant modifications, b) procedure revisions, or c) changes in facility staffing, for which the NRC may request the Company to provide implementation schedules. Such implementation schedules will be developed in discussions between the Company and the NRC consistent with the objectives of this Plan.
V. PERIODIC REPORTING The Company will submit an updated implementation schedule report to the NRC semiannually. In the updated report the Company will:
-
- Su111Tiarize implementation schedule changes since the last report.
- Identify new items added to the report.
- Surrunarize the reason for schedule changes associated with regulatory issues.
VI. MODIFICATIONS TO THE PLAN The Company and the NRC recognize that this Plan may require future modifications. Accordingly, the Company will draft proposed modifications and submit a license amendment application for approval of the proposed changes. The changes will become effective upon .amendment issuance by the NRC.
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SAFETY EVALUATION SAFETY EVALUATION PROPOSED INTEGRATED IMPLEMENTATION SCHEDULE LICENSE AMENDMENT SURRY POWER STATION UNITS 1 AND 2 The attached paragraph would modify the Surry license to require that Virginia Electric and Power Co. (the Company) follow the Integrated Implementation Schedule Plan for Surry Power Station, Units 1 and 2 (the Plan). This license amendment would remain in effect for 3 years from the date of NRC approval at which time it could be renewed if deemed appropriate by us.
The plan provides a summary description of the mechanisms for changing and updating the implementation schedules developed under the Company s Integrated 1
Implementation Schedule, the responsibilities of the NRC and our staffs with respect to the Plan and the mechanisms for modifying the requirements of the Plan.
The implementation schedules are not a part of the Plan.
50.59 Safety Review The proposed amendment and the Plan are administrative in that they commit to and provide the ground rules for negotiating schedules for major projects or commitments of interest to both the Company and the NRC. The proposed amendment does not change in any way the design or operation of the station. Consequently, the change does not constitute an 11 unreviewed safety question 11 as defined in 10 CFR 50.59 since it does not (1) increase the probability of occurrence or the consequence of an accident or malfunction, (2) create the possibility of a different type of accident other than discussed in the UFSAR; and (3) reduce the margin of safety as defined in the basis for any Technical Specifications.
50.92 Significant Hazards Review The Commission has provided standards (10 CFR 50.92 (c)) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the probability of a new or different kind of accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
This change results in additional controls on project and commitment management that are not presently included in the license. In addition, this change to the license is consistent with the NRC guidance suggested in Generic Letter 83-20 dated May 9, 1983 and Generic Letter 85-07 dated May 2, 1985. As a result, the change is in the category of Examples 2 and 7 of those types of license amendments that are considered unlikely to involve significant hazards considerations as published in the Federal Register, Volume 48, No. 67, April 6, 1983, page 14870.
Example 2 cites, 11 A change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications:
for example a more stringent surveillance requirement.
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' . e e
~xample 7 cites, 11 A change to make a license conform to changes in the
- regulations, where the license change results in very minor changes to facility operations.
Since the change would not increase the probability or consequences of an accident, create the probability of a new accident or significantly reduce a safety margin, it has been determined that a significant hazards considerations as defined in 10 CFR 50.92 does not exist.
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