ML19291E302
| ML19291E302 | |
| Person / Time | |
|---|---|
| Issue date: | 11/16/1981 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Jennifer Davis, Harold Denton, Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8112170300 | |
| Download: ML19291E302 (17) | |
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MDt0RANDUM FOR: Harold R. Denton, Director
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.s John G. Davis, Director
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Office of Meclear P,aterial Safety 1 Safeguards Richard DeYoung, Director Office of Inspection & Enforcement Robert B. Minogue, Director Office of Nuclear Regulatory Research
- FROM, Victor Stello, Jr., Deputy Executive Director Reg'onal Operations and Generic Requirements
SUBJECT:
PLA'l FOR SCHEDULING A'JD IMPLEMENTING ALL MAJOR LICD!SI!JG ACTIO!!S The enclosed draft Comission Paper, entitled "An Integrated Approach for the Scheduling and Implementation of All Major Licensing Actions,"
was sent to our Office for review.
We agree that a better approach is needed for scheduling licensing actions but the scope of the plan for scheduling such actions must be broadened to include the following:
(1) pending 'IRR requirements already approved (a) firm schedules (b) TBD schedules (2) pending IE requirements (a) firm schedules (b) TBD schedules n{k (3) pending NMSS (Safeguards) requirements
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(a) firm schedules 1
(b) TBD schedules r
(4) plant modifications and maintenance initiated by licensees omcq m._o g22;y,oos22126
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NOV 1619g1 (5) projected new requirements and new staff interpretations of existing requirements (a) by "RR (b) by IE (c) by ' MSS (d) by RES Until we have a clearer picture of the full scope of requirements for each licensee, we cennot initiate plans to develop an integrated schedule for all licensing actions for each licensee. Therefore, I am requesting that you send me a list of all pending.equirements, projected new requirements through 1932, (e.g., completed USIs, Action Plan items, P.eg Guides, final Rules, Bulletins, Orders, generic letters, etc.), and projected new staff interpretations of existing requirements (e.g.,
backfits of new SRP requirements) through 1982. This should be done on a best effort basis and submitted to me no later than November 30, 1931.
Once we have a clearer picture of the full scope of requirements, we will work with your Offices and the licensees to develop an integrated plan for scheduling all the actions required.
It may be necessary to prioritze the NRC requirements before discussing them with each licensee.
Mr. Walt Schwink will be the contact on my staff for this activity.
Please give him the name of the contact in your Office for this activity by November 18, 1931.
Original Signed by V. Stellog Victor Stello, Jr.
Deputy Executive Director Regional Operations and Generic Requirements
Enclosure:
Draft Commission Paper cc:
W. J. Dircks Distribution VStello DEDROGR cf TEb rley Central File g
DEDROGR Staff
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The subject ~of integrate'd-schedules is-broLd3nd :.T).~.! -
7 far reaching.' The scope'and. level of detai.l.ds7thee; -
attached paper _ has' been: lim.ited and-should betB-l,e
. considered a-first ~ step ~in-the evolution of-aEA ^'-
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redefinition-of DL'.s approa'ch~ to:resulationfzi '- ~.,_g.:
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the NUREG-0737 status paper presently in ccncurrence.
However, the OEper does not reflect En.rfers Ercir.g of the recently.ftrred GRRC.
Do NOT cSe this f: m es' e RE0cRD cf ep;r:vals, cenectrea.ces, dis;cse!s.
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OPT. NM. FDF.L1 t.1 (Rev. 7-76) g5{g8gCy,ny es.s.c m is o-m.s:sno 4
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For:
The Commissioners From:
William J. Dircks Executive Director for Operations
Subject:
AN INTEGRATED APPROACH FOR THE SCHED'JLING AO
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IMPLEMENTATION OF ALL MAJOR LICENSING ACT.ONS l
Purpose:
To equest that the Commission approve the imp'.e:r tation of major licensing actions by the.
use uf intecrated schedules on a plant specific basis.
Discussion:
Historically, the NRC nas imposed Y;t;uirements on Ine nuclear industry in a uncoordinated and piecemeal fashion.
NRR, I&E and NMS3 have independently imposed requirements with an adequate amount of industry feedback to ensure feasible and timely industry compliance.
Since, in the past, the total of these safety improvements did not overwhelm industry resources, licensees were able to accomplish modifications in an orderly and safe fashion during scheduled outages.
In other worcs, sufficient industry resources obviated the need to consider alternate approaches to implementing new requirements.
For the past few years the volume of pen 5ing plant modifications has far exceeced the historical norm.
Incorplete past requirements and the more recent post-TMI requirements have overwhelmed industry resources.
As tir.e has passed, the NEC staff has become more weare of the poteC-hl adverse safety implications associated with the current industry workload. This level of awareness increased with the issuance of NUREG-OSI9,,,: W. industry delineated typical problems.
2 tsequent to NUREG-0339 several licensees were surveyed whereby they further elaborated on their concerns.
(See Appendix A) This led to a staff evaluation regarding the basis for setting schedules with the objective being imoroved nuclear olant safety achievec Dv the efficient utilizati5n of staff and incustry resources.
Contact:
T. Ippolito X28059 Y
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Approach to the Develop- -
m nt of Scher. ale Several options were cor.sidered in an effort to Options:
improve NRC/ industry scheduling. Briefly, these options were:
(1) Case-hy-Case Approach - Revise
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presently existing schedules by exemptions / orders and, in the futura, establish schedules for new iters hy the use of the Generic Requirements Review Committee (GRRC); (2) Task Force Approach -
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Establish an inter-NRC task force to prioritize
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all actions and implement program by Director, Division of Licensing; (3) DL Lead Approach -
Have an outside consultant establish schedular criteria and based upon criteria review and approval, have the consultant review the schedules for each operating plant; (4) Owners' Group Approach - Have the Owners' Croup establish a model schedule with basis, and upon approval, have' licensees submit plant specific plans for NRC approval; and (5) Licensee Origin Approach -
Have each licensee submit plant specific plans with justification for NRC review and at:.roval.
These options are further discussed in Appendix B.
The evaluation contained in this Appendix concludes that the Licensee Oricin Approach is the most des i rabl e'~opti on.
This approach is discussed in the remaining sections of this paper.
It is shown schematically 'in Appendix C.
Licensee Origin Approach to Integrated Schedules:
The first step toward development of integrat 4 schedules is to establish NRC criteria upon whi.
to base the acceptance of licensee proposed schecules.
The criteria are essentially twofold:
(1) A method for establishing priorities which consider SECY 81-513 "liethod for Establishing Priorities,"
and (2) A delineation of industry decision g
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factors which allow modification of safety priorities to~reflec~ other non-safety related licensee constraints.
Once schedular acceptance criteria have been
.stablished the staff proposes, through the use of a 10 CFR 50.54(f) letter, to request from each licensee an integrated schedule for implementing the aggregate of all major licensing actions. This letter will also request licensee consent to enter into an enforceable action to comolete all items on a muteally agreed to schedule. The proposed schedule would require final implementation of all presently identified modifications by the end of the third refueling outage following the Spring of 1982.
Upon completion of the review of each plant specific integrated schedule it will be necessary to revise the schedular requirements currently in effect, and at the same time forward approval of the new integrated schedules. k'i th respect to current requirements, the staff proposes the use of an exemption aporoved by the Director, NRR which essentially canceis prior legal schedular requirements imposed by either rule or o.rder.
Concurrent with the issuance of this exemption, the i
staff proposes to issue orders that will implement the new approved integrated schedules.
The final approved integrated schedules will'be fixed and enforceable while, as noted below, retaining flexibility to adjust to new conditions. The Office of Inspection and Enforcement will continue to monitor completion of existing commitrents while the DL project manager will update plant specific performance periodically.
Schedule changes of less than one fuel cycle will be reviewed and coproved via license amendments by the Director, DL and significant schedular changes greater than, or equal to, one fuel cycle will be approved by the Director, NRR.
4
4-RECOMMENDATION: That the Comission approve the approach to plant specific integ' rated scheduling discussed herein.
William J. Dircks Executive Director for Operations
Enclosures:
Appendices A,.B and C e
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APPENDICES A.
Surma.ry of Licensee Survey B.
Evaluation of Options for the Development of Integrated Schedules C.
Schematic of " Licensee Origin" Option for the Development of Integrated Schedules e
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Accendix A Summary of Licensee Survey Over the past several weeks there were staff meetings with several licensees to ascertain schedular problems-in general and to discuss fiUREG-0737 implementa-tion in particular.
Licensees presented their views with respect to schedular prcblems associated with the timely and safe resolution of the significant backlog of plant modifications.
In addition, licensees provided their thoughts with respect to an integrated and coordinated approach to scheduling.
Participants included the Tennessee Valley Authority, the Sacramento Municipal Utility District, the Wisconsin Electric Power Company, the Power Authority of the State of tiew York, and the Maine Yankee Atomic Power Company.
.The' meeting with each licensee was informal in nature.
The major prupose was to ascertain. schedular problems being encountered by licensees.
During these meetings it became apparent that the backlog of plant modifications has increased significantly and that the most effective way to resolve this backlog was highly de' pendent on the particular plant. 'In general, the staff has imposed many differing requirements on licensees while attempting to achieve implementation for all plants on approximately the same schedule.
It did not appear to the licensees that the staff had taken into consideration the differences between-licensees when these actions were scheduled.
During the discussions the following factors became evident:
1)
Licensee inhouse engineering capabilities vary widely - the smaller the inhouse capability, the greater the dependence on engineering consultant services. When there is extensive.use of consultants the required time
.in cre as,es.
2)
Licensee procurement procedures vary dependent on the type company, i.e.,
privately vs. publicly held.
The ability to prc-cure sole source vs. the requirement for competitive bidding greatly affects vendor qualifications and delivery schedules.
In addition, expenditure authorization varies from licensee to licensee with higher organizational levels of approval generally resulting in greater time consumption.
- 3) The availability of equipment and components varies widely dependent upon "off-the-shelf" vs. " state-of-the-art" designs.
State-of-the-art designs recuire more manufacturing time. Due to high current interest rates, off-the-shelf items are requiring more manufacturing time.since vendor inven-tories are being reduced.
- 4) The availability of labor varies greatly from site to site. Dften the crafts must be shared between licensees with plants in proximity to each other.
Such sharing often results in schedular delays.
5)
Plant access is limited and varies from plant to plant. The total number of laborers allswed onsite is governei by security and health physics considerations. When more than a single modification is needed in a particular plant area, space considerations often limit the total number of workers.
2 Space. availability and limitations vary from plant to plant, Less space 6) increases the difficulty of engineering layout design and the time required-for installation.
- 7) The availability of systems for modifications is sometimes limited if such systems are shared between units at multi-unit sites.
On occasion there are overlapoing requirements for a particular system.
8)
The modification schedule for each staff requirement does not reflect the - -
varying requirements althouch it sometimes is more effective to perform all modifications on a single system at the same time.
(Sometimes modifi-cations are implemented with the knowledge that subsequent modifications may be required.)
- 9) The availability of plant outages to accomplish work is limited by power demand and grid status. Scheduling to avoid shutdowns during peak demand periods and to preclude multiple plant shutdowns at the same time is.
~
desirable.
Plant operator capability to assimilate the new designs and procedures 10)
Less associated with new requirements varies from licensee to licensee.
depth in plant operators implies more difficulty and time to safely implement changes.
In addition to the above considerations, many other less salient problem areas were discussed.
In general, all items pointed to the desirability of plant The licensees indicated specific scheduling of an integrated and coordinated nature.
that priorities could be established and urced that schedules for the most part be In the opinion tied to refueling outages rather than to arbitrary calendar dates.
of the licensees such integrated scheduling would result in more effective, efficient and safe implementation of safety upgrades.
In closing, licensees indicated a desire to submit integrated (global) schedules and, in several cases, stated such an effort could be completed within 60 days.
~
The staff indicated that if this approach were approved the method (" contract")
Finally, licensees were
- to tie down schedular commitments had not been finalized.
acvised to monitor the Commissicn's activities in this regard.
~
~
Accendix B Evaluation of Ootions 'for the Develcoment
~.
of~ Integrated Scneduies Given the objective of improved nuclear plant safety through the efficient utilization of industry and NRC resources, the NRC staff has evaluated various options.
These options essentially propose several alternative approaches toward the development of integrated schedules assuming that such a scheduling effort will be a substantial step toward meeting the above objective.
Five options are discussed herein:
(1) Case-by-Case, (2) Task Force, (3) DL Lead, (4) Owners Group, and (5) Licensee Origin.
Each approach is described and the advantages and disadvantages are discussed.
A verbal and quantitative summary is also provided which concludes that the fifth option, Licensee Origin, is the most desirable approach.
I.
Case-by-Case Accroach-A.
Description This approach proposes to grant extensions for individual safety items which currently are required to be implemented within one year.
Such extensions would be granted on a plant specific case-by-
. case basis.
In order to accomplish such schedular relief, the Director, DL, would notify licensees that the staff would consider extension requests if a firm safety basis, including justification for interim operation, were* established.
Requests for schedular relief in excess of one vear would be addressed by the Generic Requirements Review Committee (GRRC).
The Director, DL, would approve schedular relief for a one year period and, during the one year interim, the GRRC wou'd evaluate further s;hedular relief.
S.
Advantages and Disadvantages _
The advantages of this option are:
(1) The licensees will be allowed the flexibility to address the extension requests on their own schedule; (2) Tr.e approach could be executed at lower staff levels (i.e., Director, DL) with certain delegations of authority (e.g.. exemptions frr, rules, Commission Orders, etc.).
No NRC organizational cbrees or r.dditional manpower are necessary; (3) The approach has minimum impact on licensee resources needed to implement the integrated requirements approach; (4) the GRRC would be allowed a period of one year-to formulate plans and consider lonc-term actions; and (5) Input from this program would supply the GRRC insight into the industry's major problems.
The disadvantages of this option are:
(1) Completion schedules may vary widely for major programs / requirements.
No generic dates,,
whether tied to outages or otherwise, would be preestablished.
Only
2
, the justificatich for interir; operation would dictate the end date; (2) There is a potential, due to poor staff coordination and~
follow-up, that some requirements would not be implemented since no comprehensive coordinated program would be used; and (3) The near.
term staff actions may preempt or conflict with long-term GRRC plans.
II.
Task Force Aoproach A.
Description This approach proposes to prioritize all licensing issues through the use of an NRC Task Force. The Task Force would establish the safety priorities and a tentative integrated schedule for all current stfety items.
This work would result in an overall schedule frame-work which would be issued as a generic schedule to licensees for comment.
Subsequent to licensee comment resolution milestones would be established and an integrated schedule reflecting these mile-stones vnuld be sent to the Director, DL, for implementation.
B.
Advantages and Disadvantages
.The advantages of this approach are:
(1) Reliable coordination to achieve program goals and schedules.
The decision factors regarding extensions will be uniform for all plants; (2) Unifonnity among licensees regarding implementation deadlines. The sche N1e could be tied to scheduled plant outages; (3) The progress of th. 'rogram could be periodically reported as its predetermined milestons all due; (4) Upper NRR management (including GPRC) could, as des ed, have input into the program develcpment prior and subsequent to licensee input; (5) As the NRR workload ' decreases, the GRRC staff could assume the Task Force functions.
The disadvantages of this apprcach are:
(1) the near term deadlines which are of immediate concern to licensees (e.g., Mark I, EQ, etc.)
may not be addressed in this approach.
The le.ad time for program deve1coment, licensee response, and final implerentation may take up to one year.
Some programs will need to be addressed in the interim as in Option 1 This approach would be faster than the iong-term
' action of Optian I, but the resources required may nullify any significant benefit over Option I; (2) The plan is somewhat resource intensive for both the NRC and industry.
It requires manpower by both in accordance with an NRC schedule rather than letting the licensee deal selectively with the items of high priority; (3) It will, by necessity, compromise some flexibility which could be attained if the issue was addressed purely on a plant specific basis.
Any attempt at uniformity will potentially compromise the position of some licensees.
It is not probable that all licensee comments to the plan will be compatible.
4
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')L Lead 4 prccch A.
Description The approach proposes to prioritize all licensing issues through the use of outside consultants.
In this respect it is similar to the Task Force approach.
However, the responsibility for program
~~~
developrent and ivplementation would lie with the Division of Licensing, NRR.
DL would develop the criteria for prioritizing safety items.
This would be used by the outside consultant to formulate the schedule framework.
The generic schedule would then be sent to licensees and the responses evaluated by the con _s ul tant.
Plant specific coments/ problems would be resolved throagn the DL project manager. The end product would be a plant specific integrated schedule.
The Director, DL, would implement each plant specific integrated schedule.
B.
Advantaces and Disadvantaces The advantages of this approach are:
(1) It allows NRC to set / approve the program criteria while not becoming overburndened by the evaluation necessary to integrate the existir.g diverse requirenents.
Systens reviews, installation requirements etc. could be done on' contract.
Therefore, a minimum resource impact would be experienced by the NRC staff, As the present casework lessens over the next two years, the NRC ~ staff would assume more control of the plen.
Therefore, this is a flexible method from an NRC' resource
-:ewpoint; (2) It will give a superior end product.
The final plan would be Detter suited to cach plant.
A close exchaage will be obtaii.ed between the' licensee and the NRC/ consultant through the norraal commanication channels (via PM).
Therefore, the licensee will have more effect after his initial input on the end product; (3) The inal product would be more flexible than the Task Force approa:h.
The plaa utilizes the normal channels of NRC/licer.see cortcunication for its initialization.
Hence, the normal channels
-fuld continue to be utilized to effect changes in the plan. The tracking of changec, milestones, etc. could be accomplished by periodic reports submitted by the consultant.
Cnanges to the schedale will be managed by the DL project maneger for each plant.
The disadvantages of this approach are:
(1) The time delay for imple entation is similar to the Task Force Approach concerning near-term actions; (2) The cost of outside consultant assistance may be prohibitive; (3) Upper NRC Management will not be as directly involved as in the Task Force approach; (4) All requirements levied on licensees will be required to be implemented by NRR (DL).
If OIE (Bulletins) or other offices originate requirements, they must be implemented via DL for incorporation into the Plan.
Interof fice corrnunication and interface will require improvement.
However, this improvement in the long term may result from the GRRC activities;
4
. (5) Licensees are generally tired of dealing with outside consultants
' rather than the staff directly, and the approach may appear undesira'ble to the industry.
IV.
Owners Grouc Accroach A.
Description This approach proposes to use an industry Owners Group to formulate' the framework of an integrated schedule.
NRC participation in the Owners Group activities will be solely to establish safety related prioritization criteria which musc be met.
Given that the NRC criteria is met, the industry group could establish the integrated schedule.
The group would submit the schedule to NRC for approval; although the Owners Group would e no intrinsic authority, their plan wt,uld be adopted, similar to a Regulatory Guide, as an acceptable way to respond to an NRC request.
NRC would then review the plan and issue it to licensees with a request that they submit their plant specific plans for NRC approval.
B.
Advantages and Disadvantages The advantages of this approach are:
(1) It appears to maximize the industry's involvement in plan development.
It clearly establishes a policy where the NRC staff will control the safety aspect of an integrated plan and the industry / licensees conduct the planning and scheduling functions; (2) It' allows NRC to establish generic safety criteria ehich could be utilized by licensees for future actions; and (3) It would establish an Owners Group which could nomally interface with !!RR staff. (GRRL) for the implementation of new requirements.
The disadvantages of this approach are: (1) It minimizes NRC involvement in schedules. Therefore, any reqciren.ent for which the safety basis does not confine the schedule could be extended to an undesirable completion date; (2) It is somewhat industry resource intensive.
It may appear that the NRC is attempting to have industry solve the NRC stimulated problem, of a potential negative impact on safety, due to the NRC's past actions; and (3) It possesses the potential for the industry to inhibit implementation of the require-ments unless the attitude of cooperative effort is maintained.
The NRC will have to stand firm on its safs.'y criteria and the interpretations against industry efforts to achieve an acceptable cost / benefit balance. The reliance of NRC on industry efforts to achieve a solution could backfire.
V.
Licensee Origin Aoproach A.
Description The approach proposes to request that licensees provide plant specific integrated schedules with basis.
5
' The NRC staff would develop guidelines for the licensee's plar.t specific submittal. The guidelines would specify the revicx criteria but would leave to tne licensee the method to be used to justify the plant specific approach.
It would be incumbnet on the licensee to demonstrate to the NRC ctaff that his approach would not degrade the safety of operation.
Upon receipt of the licensee's program, the NRC staff would conduct review (possibly utilizing outside consultant services) and provide safety evaluation of the licensee's program. --
B.
Advantages and Disadvantages The advantages of this method are:
(1) The option is the most expedient method of addressing the problem.
The schedular guidelines could be estaMished in a short time, and licensees could begin action almost imediately. - Some near-term and all long-term actions could be addressed; (2)fLicensees could set plant unique priorities without being inhibited by a master plan. This approach provides maximum flexibility to each licensee by not setting any unifomity standards among plants; and (3) A more complete initial review may be done.
Some licensees may identify conflicts that a task force or Owner's Group might not identify.
By having so many independent plans and justifications developed, the staff can be more confident
~
that all aspects of the potential problem have been investigated.
The disadvantages of the approach are: (1)Theprogramsandcompletion dates will vary widely since minimum guidance will be given to iicensees.
The responses will be more of a function of licen:ee resources than would any other approach; (2) The option is licensee resource intensive.
Some licensees would not support s9eduling which they feel should be established by the NRC.
They would view
^
this as another resource intensive effort which would take needed personnel away from their safety related functions; (3) The review effort is NRC staff intensive.
The option requires ~ review by the NRC staff (and/or outside consultants) of an assortment of rians with different schedules, justifications, etc.
It may be diff n. ult to avoid invoking some uniform deadlines with uniform justifications for interim operation which wo:rld obviate the need for the lictnsee's original evaluation; and (4) Detailed advance planning is not pos sible.
The assumption of this method being the~most expedient may be shown to be incorrect, and the option may be shown to be the most cumbersome due to the complexity and diversity of the responses.
Summary The staff has considered these options and rated each against standard criteria.
Table B-1 shows the cirteria and the rating for each option.
The weighting factors shown have been determined based on management judgment.
A brief explanation of each criterion follows:
1.
Safety Reliability - This consideration includes the identification of' safety concerns, the fol. low-up on implementation, and the management of interim actions to guarantee safe interim operation of the plant.
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6 2.
Comple. tion time - The time required to finalize the plan, including implementation with an enforceable mechanism, on a plant specific level.
3.
Industry Resources - Resources required by licensees, A/E's, NSSS's and Vendors to develop and implement the plan.
~~4.
NRC Resources - Total staff hours necessary to develop and implement the plan.
5.
Industry Input - Input in the form of group participation, correspondence from the industry.
5.
Flexibility - This includes flexibility to effect changes to the plant and the flexibility of the ple.n tt accommodate the needs of each licensee.
7.
Requirement Unformity - The imposition of uniform technical requirements and schedules by the plan.
As shown on Table B-1, Option V is the most desirable option. Although the disadvantages of this option tre significant, consumption of industry and staff resources can be minimized through the use of outside consultants.
In summary this option represents the best compromise of all considerations.
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