ML20023C105
| ML20023C105 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 05/03/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20023C103 | List: |
| References | |
| TAC-54376, NUDOCS 8305110043 | |
| Download: ML20023C105 (15) | |
Text
,
UNITED STATES
- [')e n
NUCLEAR REGULATORY COM ISSION M
5.
'j WASHINGTON, D. C. 20555 i
,/
INTEGRATED SCHEDULING PROGRAM j
t y
EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 91 TO FACILITY LICENSE NO. DPR-49 IOWA ELECTRIC LIGHT AND POWER COMPANY DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 1.0 Introduction By letter dated May 28, 1982, Iowa Electric Light and Power Company (IELP) submitted a request (initial submittal) for approval of a five-year integrated program for implementing self-imposed and NRC-imposed modifications of the Duane Arnold Energy Center (DAEC).
The basic objective of Iowa Electric's (the licensee) program is to enable the utility to obtain b.etter control and management of which would enhance plant safety by (quired activities in a manner available resources and to perform re
- 1) improved control of safety related modifications and (2) more prompt implementation of these modifications.
On August 11 and August 12, 1982, a meeting was held with IELP and its contractor, Technology for Energy Corporation (TEC), to obtain additional information regarding IELP's submittals and discuss in further detail the licensee's program.
This meeting focused on discussing points identified in a preliminary review of the licensee's proposed program and obtaining additional information regarding the details of the methodologies and assumptions used in developing the IELP program to determine the reasonableness of the schedules proposed by the licensee.
As a result of these discussions, the licensee simplified and streamlined its submittal.
Iowa Electric requested in a November 12, 1982 application that a requirement -to follow its " Plan for the Integrated Scheduling of Plant Modifications for the Duane Arnold Energy Center" (the Plan), which was submitted with the November'12,1982 application, be added as a condition of the operating license for the DAEC.
Further discussions between the NRC and IELP identified additional areas where further clarification of and revisions to Iowa Electric's November 12, 1982 submittal were desirable.
The licensee agreed to revise its Plan (Attachment 1) accordingly in response to staff comments.
l 2.0 Program Description The progran developed by Iowa Electric utilizes a comgsterized j
scheduling technique which integrates the engineering, procurement, 1
and installation of planned NRC required modifications, and resultant i
plant operator retraining reautrements, with Iowa Electric's o,<n 1
8305110043 830503 ~
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PDR ADDCK 05000331 P
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8 requirements for plant modifications, maintenance, refueling, and operations.
The computer model used by the licensee identifies critical paths and considers the interrelationships among projects and the constraints imposed by engineering support and site manpower limitations.
The program proposed by the licensee appears to be capable of adapting schedules in the event of unforeseen delays in or installation, strikes, changes in fuel cycle schedules, procurement In. addition, the program has considered the necessity of etc.
coordinating plant modifications with revisions to plant operating procedures and operator re* training.
The licensee's program, as originally presented, proposed implementation dates as program goals and provided for semi-annual reporting to the NRC of utility progress with regard to implementation of each of the NRC required items and identification of project schedule slippages One critical assumption made in the IELP proposed program is that "NRC would not require additional plant modificat1ons during its five year period."-
However, Iowa Electric has incorporated into its program currently proposed NRC requirements which are likely to be approved for implementation on operating. reactors.
Proposed requirements (or re-quirements planned but not f.inalized, such as an upgraded suppression pool temperature monitoring system) were included for implementation in the IELP program in anticipation of HRC requirements for these items.
In addition, the licensee assumed for purposes of its program that the guidance contained in SECY 82-111 concerning Emergency Response Facilities would become requirements.
Iowa Electric indicated in its May 28, 1982 submittal some of the boundary conditions associated with its program.
For example, the program assumes in-house engineering support of some 50 personnel, which necessitated deferral of several lower priority design intensive work items.
A peak site day-shift manpower loading of some 555 personnel (1985) was set based on worker efficiency, craft availability, and effective management of these resources on-site.
The assumed in-house engineering support of 50 personnel does not include some 148,000 man-hours of engineering support outside of-IELP's Mechanical / Nuclear Engineering Department during the five-year period of interest.
Assuming approximately 1800 man-hours per work year.
this is equivalent to an average of about 17 additional man-years,per year over the five year period.
Although not specifically accounting for future new requirements (other than those currently envisaged in its present proposed program) the utility's program is structured so that additional required plant modifications can be integrated into the overall program te identify the impact of such new requirements on the overall schedule.
' The Plan submitted by the licensee identifies two categories of modifications.
Schedule A identifies schedules for modifications established by existing Rule or Order.
Schedule B identifies schedules for completion of:
1) regulatory items (of either a generic or plant specific nature) identified by NRC which would result in either a) plant modifications, b) procedure revisions, or c) changes to facility staffing requirements and which have an implementation date committed to by Iowa Electric, and; 2) items perceived by IELP as prospective NRC requirements, and; 3) all major DAEC tasks resulting from mandates of agencies other than NRC and IELP initated system upgrades for availability improvement.
3.0 Evaluation 3.1 Implementation
~
Since any major new requirement;s could result in significant schedule modifications, IELP suggested in its initial submittal that this program not be implemented by Order or License Condition.
Rather, the licensee suggested that it " report semi-annually to the NRC as to its progress with regard to the NRC required items, and as to any slippage which threatens to delay completion of such items beyond the goals specified..."
Such a program would not provide for sufficie'it accountability and leave NRC with no means of having assorance that NRC-identified regulatory issues are satisfied insofar as completion dates are concerned, short of revoking approval of the program and subsequent issuance of Orders.
In subsequent discussions with 1;censee representatives, they indicated that an Order or License Condition would be acceptable, provided that this Order or License Con-dition made provisions in some fashion for flexibility in the event that certain requirements could not be done in a timely fashion due to circum-stances beyond Iowa Electric's control.
New requirements would be incor-porated into the licensee's program after appropriate implementaion dates have been established.
The licensee's November 12, 1982, submittal (as revised) incorporates an application for amendment to incorporate a license condition requiring that Iowa Electric follow the Plan and permitting the licensee to make changes to the Plan and its schedules for certain category of items in accordance with the provisions of the Plan.
We have reviewed the licensee's Plan and have determined that
- 1) Changes to schedules for completion of modifications imposed by Rule or Order (Schedule 'A' completion dates) will continue to be sought through the 1
exemption or Order-date extension process (For example, Iowa Electric's existing request for exemption from the schedular requirements of 10 CFR 50.44 regarding hydrogen recombiner capability.) 2) Schedules for completion of other modifications (Schedule 'B' completion dates) are identified and provisions are made in the Plan to require the utility to provide the NRC with prior written notification of changes to schedule B completion dates to provide the opportunity for further explanation or discussion of such changes.
- 3) Provisions are made e
-4 in the Plan for incorporating new or anticipated regulatory items into Schedules A and B as these requirements are identified by NRC and/or formalized by Rule or Order.
The licensee's proposal to incorporate a condition into the DAEC operating license which requires Iowa Electric to follow the Plan provides an appropriate mechanism to assure that NRC is informed as to whether required safety modifications are performed in a timely manner.
At the same time, the Plan provides a suitable mechanism for changes to completion dates (due to unforseen circumstances) for modifications not imposed by Rule or Order and for keeping the NRC informed of such changes.
Thus, the degree of flexibility needed to assure effective program implementation is provided while at the same time assuring that NRC's responsibilities are not compromised.
Numerous modifications, principally NUREG-0737 items, not specifically identified in the IELP program initially submitted, were considered by the licensee as part of its " base load" of work requirements and grouped together as one or two line items in its forecasted work requirements.
The licensee identified in its November 12, 1982 submittal each planned NRC-required modification as an indiv; dual line item for inclusion in the implementing vehicle.
Semi-annual reports of utility progress towards meeting NRC required modifica-tions would be provided as proposed by the licensee.
Findings:
The proposal by Iowa Electric to add a license condition requiring the utility to follow the Plan provides a suitable mechanism for implementation of IELP's integrated plan.
Completion dates imposed by Rule or Order are unaffected by the Iowa Electric proposal.
As new requirements are identified and/or formalized by the NRC provisions are made in the Plan to incorporate these into Schedule A or B, as appropriate.
Provisions are made in the Plan to permit the licensee to develop new dates for other modifications (Schedule B) and to keep the NRC informed of such changes.
Each planned NRC required modification is individually identified in the Schedules.
3.2 Proposed Schedules Attachments 2 and 3 provide Iowa Electric's revision of its initially proposed schedule to include dates for completion of all presently known IELP-planned and NP,C-required modifications over the next five years.
For modifications imposed by Rule or Order (other than the schedule requirements of the Interim Hydrogen Control Rule) the utility proposes completion by required dates.
With respect to NUREG-0737 items, the utility also proposes completion of all NUREG-0737 items originally scheduled for completion by 1/1/82 before startup from its 1983 refueling outage as required by Order issued on March 14, 1983.
This is acceptable in view of the responsible efforts demonstrated by the licensee and the unforeseen circumstance responsible for the delay.
The licensee has shown that adequate compensatory measures are in place.
The following discusses the acceptab.ility of other completion dates proposed by IELP in its program.
With respect to items covered by SECY 82-111, schedules were developed before these items were approved by the Commission for implementation on operating reactors. In view of the responsible efforts demonstrated by the licensee, and the lead times necessary for bidding, procurement, and installations of these work items, the schedules proposed by IELP appear reasonable.
Other NRC-identified modifications whose proposed completion dates extend as late as 1986 are essentially limited to modifications associated with the issue of " Control of Heavy Loads." The licensee is conducting an extensive evaluation of this issue to determine the need for modifications to make the DAEC polar crane single-failure proof, demonstrating its responsible effort towards resolution of this issue.
As a compensatory action until modifications to this crane (if any)_ are completed, Iowa Electric has made procedural revisions and improvements to provide an increased level of safety.
We find that the necessity for conducting detailed engineering evaluations of potential nodifications to the polar crare. justifies a 1986 schedule for these codifications.
Certain schedules for completion of modifications to the Duane Arnold facility are keyed to completion of reouired NRC staff reviews that would result in sub-sequent approvals.
For example, the schedule for certain modifications re-quired by 10 CFR 50.48 is determined by the date of completion of the staff review.
In addition, certain modifications which will be necessary to satisfy the licensee's proposed radiological effluent technical speci-fications, have been proposed to be completed by the licensee on a schedule determined by completion of the staff review of this issue.
Completion dates for such items are identified in Attachment 3.
In view of the necessity of awaiting completion of staff reviews on these issues, this is acceptable.
Finally, it is recognized that with issuance of Generic Letter 82-33 pertaining to SECY 82-111, the schedules contained in the November 12, 1982 application may require some revisions.
Additionally, the licensee is awaiting final staff action on the review of Iowa Electric's exemption requests associated with Appendix R requirements.
However, a schedule update will be provided in accordance with the terms and provisions of the Plan.
Findings The completion dates for modifications proposed by the licensee in its November 12, 1982 submittal show IELP's responsible efforts towards satisfying NRC requirements.
Where the dates proposed by the licensee extend more than about three years in the future, initial action vill have been taken-by the licensee to provide a high level of safety.
Modifications which extend into 1986 or 1987 are of such a nature that full compliance could not reasonably be expected to be attained much sooner.
Dates for completion of modifications not yet determined due to the necessity of awaiting staff approval will be included in the licensee's plan after the ' requisite staff reviews are complete.
,)
i Based upon our review of the information contained in IELP's submittals, the dates proposed by the licensee in its November 12, 1982 application appear reasonable.
- 4. 0 Sumary Based on the considerations addressed herein, we find that:
- 1) 'he proposal by Iowa Electric that its plan be implemented by a License Condition requiring the utility to follow the Plan is accepta bl e.
2)
The licensee's proposal 'that changes to implementation dates imposed by existing Rule or Order will continue to be sought through the exemption or order date extension process is acceptable.
- 3) Schedules for new requirements should be established for the DAEC on a plant specific basis.
- 4) Based upon our review of the dates proposed by the licensee in its November 12, 1982 submittal, the dates p'roposed by the licensee appear reasonable.
5.0 Environmental Consideration We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement, or negative declaration and environ-mental impact appraisal need not be prepared in connection with the issuance of this amendment.
6.0 Conclusion We have concluded, based on the considerations discussed above, that:
(1) because the amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated, does not create the possibility of an accident of a type different from any evaluated previously, and does not involve a significant reduction in a margin of safety, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Date:
May 3, 1983 Principal ~ Contributor:
Kenneth T. Eccleston i
Attachme#t 1 Plan for the Integrated Scheduling of Plant Modifications for the Duane Arnold Energy Center I.
. Introduction Iowa Electric Light and Power Company (IELP) has. developed a comprehensive program which will enable the Company to effectively manage implementation of certain modifications
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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 the Company.
A description of the program, identified as " Integrated Program for Modifica-tion of the Duane Arnold Energy Center (DAEC), " was submit-ted to the NRC on May 28, 1982, by Iowa Electric letter LDR-82-0140.
This program was developed to coordinate and sched.ule all necessary work at the DAEC, whether mandated by-NRC or identified by IELP and others.
The program objectives are to (1) conform to regulatory requirements; (2) provide sufficient lead times for modifications; (3) minimize 3
changes for operators; (4) assure training requirements are fulfilled; (5) effectively manage financial and human resources; and (6) specify the framework for changes to developed schedules.
This program reflects that fiscal and manpower resources are finite and that a limit'on the onsite manpower is neces-sary.
The program integrates all presently. planned work at DAEC over a nominal-five year period to ensure that in-
'dividual tasks are effectively scheduled _and coordinated.
It provides a.means for new requirements to be accommodated-taking into account schedule and resource constraints.
The purpose of this document is to describe the plan used to implement the program (the " Plan").
It describes how;the i
program functions, mechanisms for changing the Plan and updating it, and the interactions of-NRC and licensee staf fs under the Plan, and its associated schedules.
II.
Summary of Program Development The program is based on-a computer' generated listing of over 600 items of prioritized work.
The listing takes into account projections'for budgets and site manpower'and
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engineering support requirements for ~five years, on ;an item-by-item basis covering all: plant modification activities..
It represents a total DAEC work list and commitment list which is regularly modified and.~ updated to meet changing 1
conditions, including new NRC regulatory requirements.
The final product of this program is the development of schedules -
as discussed below.
'i e-
)
III. Scheduling Upon completion of the complete work listing, Iowa Electric determined that detailed and integrated schedules were required'for the major work items.
Upon completing the comprehensive listing of, major work items, the tasks were organized into Schedules A and B using critical path methodology (CPM) for selected work items.
CPM schedules identify critical paths in the work effort for each task, which in turn, enables prompt ad-aptation of schedules to meet contingencies such as strikes, delays in procurement or installation or modification of fuel cycle schedules.
Both Schedules are briefly described below:
Schedule A -
All items which have imple-mentation dates mandated by NRC rules, orders, or license con-ditions.
Schedule B -
Regulatory items (of either a generic or plant specific nature) identified by NRC which have im-plementation dates committed to by Iowa Electric and which would result in either a) plant modi-fications, b) procedure revisions, or c) changes in facility staf-fing requirements; or-i tems perceived by Iowa Electric as prospective NRC requirements; or major DAEC tasks resulting from mandates of agencies other than NRC and IELP-initiated system upgrades for availability improvement.
Schedule A dates may be modified only with the prior approval of NRC, in accordance with existing NRC procedures.
Changes in Schedule B dates require written notification to NRC as described in Section V.
Schedules 'A and B, t'aken together, provide a basis for assessing the overall effects of changes to schedules and a departure point for discussion between NRC and the licensee regarding such changes, as dis-cussed below.
IV.
Schedule Modifications An important aspect of Iowa Electric's planning effort is the' recognition:that the attached schedules will nr.ed to be 4
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modified at times to reflect changes in regulatory re-quirements, to accommodate those activities that Iowa Electric finds necessary to improve plant efficiency and reliability, and to take into account delays resulting from events beyond IELP's control.
It is important that the procedure used by Iowa Electric for changing the schedules be documented.*/ In addition, the NRC must play a role in the oversight of the scheduling process (and must, in fact, judge the acceptability of proposed date changes in Schedule A).
Accordingly, it is important that the NRC's role, and the interaction between the NRC and IELP, be clearly defined, as discussed below.
V.
IELP Responsibilities The integrated schedule requires that IELP monitor the progress of all work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actiens when a schedule change is needed.
A.
Periodic Updating IELP will update Schedules A and B semi-annually and submit the revised schedules to NRC, beginning six months following NRC concurrence in the Plan.
In addition to updating the schedules, IELP will:
Summarize progress in implementing NRC requirements concerning plant modifications Identify changes since the last report Summarize the reasons for schedule changes associated with regulatory requirements.
4 B.
Changes to Schedules Changes to the schedules may arise from a variety of reasons, such as new work activities; modifications in the scope of
- /
Schedules A and B will contain sufficient detail to
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identify those items with completion dates keyed to fuel cycle outages.. In such. cases, a change in outage period shall not be' considered a schedule change.
e
scheduled work; problems in delivery, procurement, etc.;
changes in NRC rules and regulations; or other NRC or IELP actions.
Where it is necessary to add a new work item or to change the schedule for an item, the following general guidance will be utilized to the extent appropriate:
Assess the priority of the work item and its safety significance Schedule the new or changed item to avoid rescheduling other items, if it can be reasonably achieved Alter Schedule B items before Schedule A items Select a schedule for the new or changed item which will help in maintaining an optimum integrated program of work.
As noted above, no changes will be made in Schedule A without prior NRC approval.
Should a change become neces-sary, it will only be proposed after Iowa Electric has determined that rescheduling of non-NRC required work items either will not significantly assist in maintaining Schedule A without change; or,that the safety, cost or schedule penalties from rescheduling non-NRC required work sig-nificantly outweigh the change in a Schedule-A completion date.
Iowa Electric will inform the NRC Project Manager when serious consideration is given to requesting a change in Schedule A.
When IELP determines that a change in Schedule A is necessary, it will submit a written request for NRC approval in accordance with applicable procedures.
Work items in Schedule B may be rescheduled or work items may be added to Schedule B by Iowa Electric without NRC i
approval; however, IELP will inform the NRC Project Manager when serious consideration is given to changing the schedule for or adding an item in Schedule B.-
In addition, at least 30 days (unless otherwise agreed to by the NRC Project flanager or unless circumstances beyond IELP's control arise within 30 days of the scheduled date) before IELP adopts a
1.
change for an item in Schedule B (as defined in Section III above),
it will provide the NRC written notification thereof, including the reasons therefor and any compensatory actions instituted.
If not provided 30 days in advance, such notification will be provided by IELP as promptly as practicable.
NRC may request further explanation or discussion concerning such change.
In this event, discussions will be initiated with the NRC Project Manager However IELP changes in scheduled dates will be effective unless s.ubsequently modified by IELP.
VI.
NRC Review As pointed out in Section V.B above, changes to the sched-ules are inevitable.-
Action required by NRC is discussed below:
A.
Iowa Electric Originated Changes 1.
Upon receipt from IELP of a request for modi-fication of Schedule A, NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the re-quest in accordance with applicable procedures.
2.
If the request for a modification of Schedule A is denied, NRC shall promptly inform Iowa Elec-tric and provide the reasons for denial.
2 3.
NRC consideration of IELP changes in non-Schedule A items is covered by V.B.
B.
NRC Originated Changes (Schedule A)
It is recognized that formal NRC regulatory actions may:
(1) impose a new regulatory requirement with a fixed date or (2) establish a firm date for a previously identi-fied 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 IELP's ability to complete effectively the items on Schedules A, and-B, and, in consultation with IELP, will try to minimize such impact.
Although any formal regulatory action taken by the NRC will be effective in accordance with its terms without inclusion in Schedule A, the NRC and-IELP recognize the desirability of. incorporating such action into Schedule A, particularly in order to-incorporate at the same time any other appropriate _ changes In the total integrated schedule program.
necordingly, once such formal. regulatory action is taken (or earlier, if
< practicable), the NRC will provide IELP a reasonable op-portunity to propose overall changes in the total integrated schedule program which would most effectively accommodate such requirements.
Any resulting changes in items in Schedule A will be approved by NRC in accordance with established procedures, and will thereupon be reflected in a revised Schedule A submitted by IELP.
IELP will inform the NRC of any resulting changes in Schedule B in accordance with Section V. above.
C.
New NRC Issues (Schedule 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.
For issues as to which NRC requests scheduling information, these issues may be included in Schedule B in accordance with the date commitment developed in discussions between IELP and the NRC staff.
As for the case of NRC-originated changes to Schedule A items, the NRC will provide IELP a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accommodate such issues.
Any resulting changes in integrated program schedules will thereupon be reflected in a re-vised Schedule B submitted by IELP.
VII. Modifications to the Plan The licensee and the NRC recognize that the Plan itself may require future modifications.
Accordingly, IELP will draft proposed modifications and submit a license amendment application for approval of the proposed changes.
The changes will be made effective upon amendment issuance by NRC.
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