ML20079M383

Draft Integrated Living Schedule Program Plan

ML20079M383
Person / Time
Site:	Davis Besse
Issue date:	01/20/1984
From:	TOLEDO EDISON CO.
To:
Shared Package
ML20079M376	List: ML20079M373 ML20079M383
References
PROC-840120, NUDOCS 8401270297
Download: ML20079M383 (14)

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l DRAFT TOLEDO EDISON COMPANY - DAVIS-BESSE NUCLEAR POWER STATION INTEGRA'IED LIVING SCHEDULE PROGRAM PLAN I. Introduction A. Purpose Toledo Edison Company (TED) determined that the effectiveness of the overall management of it's Nuclear Mission would be enhanced if its budgeting, project management,1 planning and scheduzing activities for Plant improvement or modification (" Plant better-ment") project;/ issues were combined into a single integrated program. This integrated program has been designated as the

" Integrated Living Schedule Program" (ILSP).

The purpose of this " Plan" is to establish, within the ILSP framework, a rational basis upon which TED and the United States Nuclear Regulatory Commission (NRC) will fulfill specific responsibilities as related to the Davis-Besse Nuclear Power Station (Davis-Besse).

B. Objectives The primary objectives of the ILSP Plan are:

1) To optimize the allocation of TED and NRC resources among those activities necessary to assure safe, reliable and economic operation of Davis-Besse.

2) To achieve the appropriate balance and prioritization between TED initiated activities and NRC required activi-ties, thereby providing a defensible and consistent basis for planning, scheduling and implementing necessary plant betterment projects at Davis-Besse.

C. Plan Content This Plan contains four (4) sections as identified below:

Section I - Presents the purpose, objectives and content for the Plan.

1 Project Management includes Nuclear Facility Engineering, Material Management, Nuclear Projects, Station Management and Licensing.

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2-Section II - Describes the ILSP as it is being implemented by TED.

Section III - Identifies the " schedules" that will be generated by TED as part of the ILSP prccess. This Section also specifies the process and responsibilities of TED and the NRC with regard to modifications of the " schedules".

Section IV - Specifies the basis for TED and NRC implementa-tion and enforcement of this Plan.

II. Description of TED Program A. General The ILSP process has been incorporated by TED into the normal management activities of the Nuclear Mission. In this regard, TED has defined the ILSP as stated below:

The Integrated Living Schedule program optimizes the implementation of plant betterment activities to best use the limited resources of both the NRC and TED. By utilizing a rational process of identifying, integrating, prioritizing, planning and scheduling plant betterment activities, considering safety, regulatory, reliability, operability and economic factors as well as financial, hardware and human constraints, it optimizes the allocation of resources for assuring the safe, reliable, economic operation of Davis-Besse.

Figure 1 shows a simplified flow diagram of the ILSP process.

The activities shown on Figure 1 can be separated into function-al areas of: 1) Issue / project evaluation; 2) Prioritization activities; 3) Planning and Scheduling; and 4) Implementation.

While each of these functions were always a part of TED's management activities, the integration of these functions into a single coherent program makes the effectiveness of the whole program greater than the sum of the parts. This plan addresses such an integrated program.

Considering the functional areas of activity in a general way, issue / project evaluation includes those activities associated with performing conceptual engineering, economic and safety assessments of both NRC and TED identified issues (plant betterment projects).

An important aspect of the issue / project evaluation function is the " technical" integration that takes place during these activities. Basically, technical integration entails determin-ing how issues or projects affect each other and defining

whether combinations of issues or projects could reduce the scope of planned activities and result in an improved plant design.

Prioritization activities are a critical compenent of TED's ILSP. These activities are intended to provide a consistent and appropriate basis for planning and scheduling the major plant betterment projects recognizing a set of appropriate prioriti-zation factors (e.g., safety, reliability, economics, etc.).

The planning and scheduling function includes those activities required to produce a comprehensite, prioritized and resource loaded schedule of plant betterment projects determined by TED t' he applicable to Davis-Besse. This function must be capable of accommodating the output of the prioritization activities as well as to rationally impose the resource and other practical constraints that govern TED's ability to perform the plant betterment projects in the most cost-effective manner.

Additionally, this function mast have the capability to accommodate additions to and modifications of schedules.

The implementation portion of TED's - ILSP refers to the actual implementation of the plant betterment projects and to the use of the ILSP in the management of TED's budget process.

B. TED Program

1. ILSP Management -

Implementation of the ILSP process at TED involves each Division in the Nuclear Mission (See Figure 2) and has resulted in the modification to TED-Nuclear Mission procedures and policies to formally internalize the pro-gram. While the Vice President, Nuclear is ultimately responsible for the program, day-to-day responsibility for assuring that the program is functioning has been assigned to the Davis-Besse Work Scope Committee (DBWSC).

The DBWSC is composed of at least four members including as a minimum the Station Superintendent and the Directors responsible for Engineering, Licensing and Nuclear Pro-jects. The DBWSC is responsible for directing the preparation of the overall ILSP schedule and to review proposed changes to schedules developed through the ILSP, recommending to the Vice President, Nuclear what action should be taken. The DBWSC is also the management entity responsible for recommending the annual capital budget projects and :najor operation and maintenance projects to the Vice President, Nuclear. In essence, the DBWSC represents a senior management committee providing an overviry and centralized management of the ILSP.

2. Issue / Project Evaluation TED utilizes a " Facility Change Request" (FCR) process that involves the preparation of an FCR for proposed plant betterment projects. In addition, Suramary Level Planning Worksheets (SLPW) can be developed to evaluate projects / issues.

The FCR and SLPW process includes preparation and review of documentation supporting the need for the FCR (capital and major maintenance FCR's) and the evaluation of alternatives for addressing the specific issue. As part of TED's formal FCR process, required safety reviews, safety evaluations and assessments are also performed. TED will modify, or develop procedures to integrate the activities of the FCR process into the.ILSP. In addition, as discussed subsequently, TED has supplemented the existing FCR review process with specific activities in the ILSP process that are intended to achieve " technical integration" and improve the planning and scheduling input data. This extension of the FCR process and its coordination with the ILSP, forms an integrated syrtem of TED resource management directed at improved plant safety and performance.

3. Prioritization The prioritization function has been developed as part of the evolution of the ILSP process at TED. In this regard, TED considers the prioritization process to be dynamic and expects to make improvements to the process as better information (e.g. , plant specific reliability models) and improved methodologies become available.

The prioritization sctivities are performed under the auspices of the DBWSC. Specifically, a "Prioritization Subcommittee" reporting directly to and guided by the DBWSC has been established. The subcommittee is composed of designated individuals from the Station and the Nuclear Safety, Nuclear Projects, Nuclear Facility Engineering Divisions identified on Figure 2, except Quality Assurance.

Individuala are assigned to the subcommittee by the DBWSC.

In making such assignments, the DBWSC assures that a broad spectrum of expertise and experience is represented on the subcommittee. Additions or changes to the subcommittees membership can be made on a permanent, or temporary basis as deemed necessary by the DBWSC. It should be emphasized that a specific intent of the committee concept is to establish a broad-based hignly experienced teac that will perform the prioritization function in a consistent rational and defensible manner.

Applicable issues and plant betterment projects being considered for inclusion in the ILSP are prioritized by the subcommittee with respect to the following prioritization factors:

1) Nuclear Safety i 2) Plant Reliability / Availability

3) Personnel Safety

4) Regulatory Significance

5) Economics / Practicality The subcommittee assigns a priority designation to each

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issue / project for each of the prioritization factors identified above. Specific criteria are predetermined for each prioritization factor to guide the deliberations of the subcommittee.

In summary, the prioritization process is accomplished using identified criteria within the framework of a formal 1 2 cess that utilizes a highly qualified and experienced group of individuals.

In addition to the prioritization function, the subcommit-tee also provides a forum for overviewing the validated SLPW's for each project and for identifying opportunities for batter technical integration among issues / projects.

4. Planning and Scheduling TED utilizes a Project /2 computerized planning and schedul-ing system. The planning and scheduling function is per-formed under the direction of the Nuclear Projects Division.

Figure 3 illustrates the basic summary level planning information that is input to the system. Project /2 has the capability to plan and appropriately schedule multiple projects and activities considering the relative priorities of the projects and allowing the imposition of planning constraints. In this regard, as part of the planning process, the DBWSC can identify constraints (e.g., number of craf ts onsite, maximum number of workers in an area, etc.) that are input to the planning and scheduling activities to achieve a realistic output of what can be accomplished over a specific time period (e.g., budget year, planned outage period, etc.).

TED updates the Project /2 system information on a regular basis to manage the implementation of projects and to identify schedule problems, or opportunities to accomplish additional activities. The status of the activities are regularly reported to the DBWSC by the Nuclear Projects Division with recommendation of actions that the DBWSC should consider taking. This process allows TED to make appropriate changes to project schedules when they are affected by acti/ities such as unscheduled outages, strikes, delays in procorement or installation, modifications to fuel-cycle schedules.

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S. Implementation The implementation function of the ILSP involves both the actual implementation of the projects included in the schedule and the relationship of the ILSP process to TED's annual budgeting process.

First, with respect to the actual implementation of pro-jects included in the schedule, TED has established a formal project management process that resides with the Nuclear Projects Division. Each project is assigned to a specific project coordinator who reports to a derignated project manager. The status of discrete activities (e.g.,

engineering, equipment status, construction, etc.) are monitored relative to the Project /2 planning networks by the project coordinator and reported to the project manager.

Regularly scheduled project status reports are issued and as stated previously, the DBWSC is notified of circumstances that could affect the adopted ILSP " schedule".

The utilization of a formal project management process that has available the comprehensive planning and scheduling information provided by the Project /2 system, yields a high degree of confidence that the planned projects will be accomplished in accordance with TED's ILSP commitments.

A second area of ILSP implementation that should be ac-knowledged in this Plan relates to the development of budgets. Capital, operations and maintenance budget items must be approved by the TED Board of Directors prior to expenditure of funds for the projects. Therefore, at the beginning of the budget approval process, the DBWSC supported by the Prioritization Subcommittee and the Nuclear Projects Division prepares a recommended budget, based upon the ILSP process, and submits it to the Vice President, Nuclear.

The actual implementation of the ILSP recommended activi- ,

ties cannot be initiated until the TED Board of Directors approves the re.ommended budget. Furthermore, if changes (i.e. , cost increases, or the addition of new projects) are

made to the ILSP recommended projects (See Section III) subsequent to the approval of the budget, approval of the modified budget must be obtained.

III. Schedule Identification and Modification A. Schedule Identificatica -

j The basic output of the TED-ILSP process will be a schedule that has rationally planned and prioritized applicable plant betterment activities as identified by TED, or required by the NRC and c:t7r agencies (i.e. , INPO, FAA, OSHA, etc.). In this regard, l TCP has determined that this schedule will be comprised of two l

components, designated as the " Implementation Schedule" and the "Long Range Plan".

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The Implementation Schedule will extend over approximately a two-year duration and will reflect the schedule for capital and major operations and maintenance projects approved by the TED Board of Directors in the current year's budget. The unbudgeted Long Range Plan could overlap the Implementation Schedule beyond its' first year and will extend over a period of between one and five years. The Long Range Plan will identify known, but currently unbudgeted capital and major operation and maintenance activities. Included in both the Implementation Schedule and the Long Range Plan will be a variety of plant betterment activities, which from a regulatory perspective, have differing significance. In recognition of this fact, the types of activities that may be included have been categorized as follows:

1) Category A - Activities that have implementation dates mandated by NRC rules, orders or license conditions.

2) Category B - Davis-Besse specific NRC requirements that are not in Category A, but have been budgeted and included in the Implementation Schedule.

3) Category C - TED identified plant betterment activities that are included in the Implementation Schedule or Long Range Plan.

4) Category D - Davis-Besse specific NRC requirements that are not budgeted, but are included in the Long Range Plan.

B. Schedule Modifications

1. General An important aspect of TED's-ILSP process is the recogni-tion that the Implementation Schedule and Long Range Plan will need to be modified at times; to reflect changes in regulatory requirements, to accommodate additional TED identified plant betterment projects; or, to reflect delays resulting from events beyond TED's control. Therefore, it is necessary for this plan to identify the process by which such schedule modifications will occur and the explicit responsibilities of both TED and the NRC regarding such changes.

As described previously, TED has centralized the management of the ILSP with the DBWSC and will be regularly monitoring the status of the ILSP schedule and plan through its internal project management process. Therefore, in the event delays to scheduled activities occur, the DBWSC will be aware of the situation and will be responsible to assure that the appropriate actions, are taken.

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With regard to the incorporation of a new (or revised) regulatory requirement, or new (or revised) TED plant betterment activity, TED will address the new (or revised) activity consistent with its ILSP process. Specifically, upon completion of the necessary evaluations and documentation, the new activity will 1) be submitted to the prioritization subcommittee for action; 2) incorporated, based upon its priority designations, into the Implementation Schedule, or Long Ranga Plan. If the activity is determined to be an Implementation Schedule item, the Nuclear Projects Division will inform the DBWSC of whether it can be accom-plished without exceeding the currently approved budget, what additional budget may be required, or what planned projects could be rescheduled to allow the new activity to be performed in light of the adopted planning constraints.

If the new activity is determined to be a Long Range Plan item, the Nuclear Facility Engineering Division will incorporate the project into the existing Long Range Plan.

The DBWSC will recommend appropriate action to the Vice President, Nuclear and assure that the TED responsibilites are satisfied.

2. TED Responsibilities TED has the following responsibilities regarding coordina-tion with the NRC of modifications to the Implementation Schedule and the Long Range Plan: 2 a) Category A items - Scheduled completion dates for Category A items, whether on the Implementation Schedule or the Long Range Plan will be modified only upon receipt of prior approval from the NRC, in accordance with applicable NRC regulations.

TED will inform the NRC Project Manager for Davis-Besse when serious consideration is being given to requesting a change in the completion dates3 for Category A items.

2 The Implementation Schedule and the Long Range Plan will contain sufficient detail to identify those items with completion dates keyed to fuel cycle (planned) outages. For such items, a change in outage period shall not be considered a schedule modification. In addition, for items in the Implementation Schedule and Long Range Plan, changes I to project completion dates prior to completion of design shall not be considered a schedule modification.

3 For purposes of responsibility discussions in this Plan, changes to the scheduled dates for intermediate activities that do not jeopardize, or change the scheduled completion date, do not require prior NRC approval, or notification.

-9 b) Category B items - TED will inform its NRR Project Manager when a change is made to the scheduled completion date for a Category B item. TED will provide the NRC with written notification of a change including the basis for the change and any compen-satory action initiated.

NRC may request further explanation, or discussion concerning such changes. In this event, discussions will be initiated with the NRR Project Manager.

However, all changes in Category B scheduled comple-tion dates will be effective immediately and will remain so unless subsequently modified by TED.

c) Category C items - As part of the semi-annual update of the Implementation Schedule and Long Range Plan (See Section IV), TED will advise NRC of changes to Category C items. With the exception of the situation indicated below, prior notification to the NRR Project Manager of changes to items in this category will not be required.

If, however, TED modifies a Category C item that was included on the Implementation Schedule and that was previously the basis for modifying the completion date for a Category A item, TED will inform the NRR Project Manager, consistent with the guidance stated previously for Category B items, d) Category D items - As part of the semi-annual update of the Long Range Plan (See Section IV), TED will advise NRC of changes to Category D items. No prior notification to the Project Manager of changes to items in this Category will be required. If after the semi-annual review, NRC desires additional informa-tion, such discussions will be initiated with the NRR Project Manager. However, all changes in Category D scheduled dates will be effective immediately and will remain so, unless subsequently modified by TED.

3. NRC Responsibilities i 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 identified regulatory requirement. In addition, the NRC may identify new regulatory issues that could ultimately be determined to be plant specific to Davis-Besse requiring plant modifi-cations, procedural change, or staffing changes.

In taking any of the actions identified above, the NRC, to the extent consistent with its' overall regulatory respon-sibilities and, unless public health, safety, or interest

. require otherwise, will recognize TED's ILSP process as set forth in this Plan. Specifically, to the extent possible, the NRC will not specify completion dates, but will request TED to incorporate the "new" requirement into its ILSP process and to respond to the NRC regarding completion of the requirement consistent with its priority relative to the items already in the Implementation Schedule and Long Range Plan.

For new items deemed by the NRC to be significant enough to warrant inclusion in the then existing Implementation Schedule, the NRC shall request a response from TED within 90 days. This response shall identify the proposed comple-tion date for the activity, the basis for that date, the impact on the Implementation Schedule and any compensatory actions TED proposes to initiate. TED shall also specify the latest date for receipt of NRC concurrence that would still allow the proposed schedule to be met.

For new regulatory items considered by the NRC to be applicable for inclusion in the Long Range Plan, TED shall inform the NRC of the Proposed schedule as part of the semi-annual update (See Section IV).

In making judgments concerning whether a new requirement should be considered to be included in the Implementation Schedule, or Long Range Plan, the NRC will maintain cogni-zance of the activities TED has already committed to accomplish, the timing relative to budget cycle and outage schedule when the new requirement is being imposed and the responsibilities of the NRC as mandated by the Atomic Energy Act and the Energy Reorganization Act.

IV. Program Implementation and Enforcement A. Responsibility -

The primary TED interface with the NRC regarding this Plan and its implementation will be the Nuclear Licensing Manager.

The primary NRC interface with TED regarding this Plan and its implementation will be the NRR Project Manager for Davis-Besse.

In recognition of the regionalization concept being contemplated by the NRC, TED will copy both the Director, Division of Engi-neering and Technical Programs in Regior. III and the Site Resident Inspector on correspondence relevant to the Plan, However, for purposes of consistency and accountability, the imposition of new NRC regulatory requirements that are to be considered for inclusion in the ILSP - Implementation Schedule, or Long Range Plan shall be formally submitted to TED through NRC Headquarters.

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Neither the Implementation Schedule nor the Long Range Plan are considered to be formal parts of this Plan, or associated license amendment. However, consistent with applicable NRC regulations, Category A items represent formal regulatory commitments. In addition, consistent with the provisions of Section III - B.2 of this Plan, for Category B items and specific Category C items TED is required to notify NRC of completion schedule changes thereto. In this regard, enforce-ment of these schedule commitments under applicable NRC require-ments should be consistent with the provisions of the Plan and apply to completion dates only, and not to intermediate activity schedule dates.

On a semi-annual basis, commencing approximately six (6) months following approval of this Plan, TED will update the Implementa-tion Schedule and Long-Range Plan and advise NRC of their status. Specifically, TED will:

Summarize progress in implemention of Cstegory A and B projects.

If applicable, summarize the reasons for schedule changes associated with Category A and B projects.

Identify item or completion date changes to the Implementation Schedule and Long-Range Plan since the last update.

C. Plan Modification The licensee and the NRC recognize that the Plan itself may require further modification. Accordingly, TED will perform the necessary reviews, consistent with NRC regulations, associated with proposed plan modifications and if determined necessary will submit a license amendment application to the NRC for approval of the proposed changes. In such cases, the changes will be made effective upon amendment issuance by th,: NRC.

PD 4005B/4-15

Serial N o. 996 January 21, 1984 *

) Figure 1 Toledo Edison Company INTEGRATED LIVTNG SCHEDULE PROGRAM Simplified Process Flow I

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Assessment of I Identification of Issues / Projects

Prioritization of  :: Alternate Solutions 2: Prioritization of  ::

Issues / Projects Issues / Projects Projects l l1 Il l Identification of Work Package

---4> Work Scope  : Implementation  : Design 3: Implementation I

Budget Approval Schedule Eng. Procurement Bulk Procurement jk AL Ak h

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Serial No. 996 FIGURE 2 January 21, 1984 TOLEDO EDISON COHPANY - NUCLEAR HISSION ORGANIZATION CHART NUCLEAR Vicehessent l

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