ML20096B831
| ML20096B831 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/04/1996 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| Shared Package | |
| ML20096B827 | List: |
| References | |
| NUDOCS 9601160433 | |
| Download: ML20096B831 (43) | |
Text
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UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA Docket No. 50-361 EDIS0N COMPANY, ET AL.
for a Class 103 License to Acquire, Possess, and Use a utilization Facility as Part of Amendment Application Unit No. 2 of the San Onofre Nuclear No. 155 Generating Station j
SOUTHERN CALIFORNIA EDIS0N COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 155.
This amendment application consists of Proposed Change Number (PCN)-455 to Facility Operating License No. NPF-10.
PCN-455 deletes License Condition 2.C(26), " Integrated Implementation Schedule." License Condition 2.C(26) requires implementation and maintenance of a plan for scheduling all capital modifications based on an NRC approved Integrated Implementation Schedule Program Plan.
9601160433 960104 PDR ADOCK 05000361 P
pyg
e' Subscribed on this QTA day of JApuny
,1996.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By
~DwightV. Nunn Vice Prtsident State of California County of Geenge Jan 7.*aye f
On I(y/qL betore me 3,44MgA A. /fcCAATHY/UcTMf PutLIet perso'nally appeared,Pw Ice,E. Nu uv
, personally known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.
WITNESS my hand and official seal.
Signature M t h O.
'^^--------
m BARBARA A. MC CARTHY "g
COMM. # 1062179 3
3 Notary P25c - Co#fornia S
]
ORANGE COUNTY y
1 MV Conn. Eg*ee MAR 31,1999 g l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA Docket No. 50-362 EDIS0N COMPANY, ET AL.
for a Class 103 License to Acquire, Possess, and Use a Utilization Facility as Part of Amendment Application Unit No. 3 of the San Onofre Nuclear No. 139 Generating Station SOUTHERN CALIFORNIA EDIS0N COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 139.
This amendment application consists of Proposed Change Number (PCN)-455 to Facility Operating License No. NPF-15. PCN-455 deletes License Condition 2.C(27), " Integrated Implementation Schedule."
License Condition 2.C(27) requires implementation and maintenance of a plan for scheduling all capital modifications based on an NRC approved Integrated Implementation Schedule Program Plan.
i l
4 Subscribed on this F4 day of 7AnaAA.V
,1996.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:
,bL k ( b __
" GWight
. Nunn' Vice Pr sident 1
i State of California County of Grenge JAM DlE6 C' On if4/ql before me, MBAk A f). HecArrHYlmrALY he, LIE persohally appeared 1)w igg r E. A/t4 vv
, personally known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.
WITNESS my hand and official seal.
Signature M ( % (l. N/ C %
j I
mmm f
COMM. # 1062179 g
-l Notary PLMc - Cdfomio E
ORANGE COUNTY y
{
My Comm.E**ee huR 31.1999)
I i
i ENCLOSURE 1 DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-10/15-455
DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-10/15-455 This is a request to delete License Conditions 2.C(26) and 2.C(27),
" Integrated Implementation Schedule," for San Onofre Units 2 and 3, respectively.
Units 2 and 3 License Conditions Existing License Conditions Unit 2: See Attachment "A" Unit 3: See Attachment "B" Proposed License Conditions Unit 2: See Attachment "C" Unit 3: See Attachment "D"
1.0 DESCRIPTION
OF CHANGES:
This amendment request is to delete License Conditions 2.C(26) and 2.C(27), " Integrated Implementation Schedule," for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, resp (ectively.
These license conditions require Southern California Edison Edison) to implement and maintain a plan for scheduling all capital modifications based on an approved NRC Integrated Implementation Schedule (IIS)
Program Plan.
2.0 BACKGROUND
On August 28, 1986, Edison submitted PCN-218 (Reference 1) to the NRC.
It requested a new license condition relating to an Integrated Living Schedule (ILS) for Backfits which was consistent with the recommendations of Generic Letter 83-20, " Integrated Scheduling for Implementation of Plant Modifications" (Reference 2). This PCN was subsequently modified by letters dated November 21, 1986 (Reference 3) and February 1, 1988 (Reference 4) to be consistent with the NRC approved Plan and license condition for the SONGS 1 unit. Additionally, the Plan's name was changed to Integrated Implementation Schedule.
On May 15, 1989, License Amendment Nos. 72 and 60 established an Integrated Implementation Schedule Program via License Conditions 2.C(26) and 2.C(27) (Reference 5) for SONGS 2 and 3, respectively. The goal of this program is the implementation of capital modifications in a stable, controlled manner.
Projects with the greatest potential of enhancing the safe operation of the units are given the highest priority.
The license conditions require Edison to update its schedules of capital modifications on a semi-annual basis.
t 9
l
3.0 DISCUSSION
The IIS methodology (Reference 6), which was approved by the NRC, utilizes the Westinghouse Analytical Ranking Process (WARP) to determine the relative potential safety significance of each regulatory committed modification. The methodology requires that after the projects are ranked, they be evaluated using normal scheduling methods to determine their implementation schedules. The highest ranked projects are evaluated first and scheduled for the earliest outage in which implementation constraints of a normal refueling outage would not be exceeded. The schedules of each unit are then separated into the following three lists as described below:
Schedule A All items which have implementation dates required by NRC regulations, orders or license conditions.
l l
Schedule B l
Regulatory items (of either generic or plant specific nature) identified by the NRC which have implementation dates committed to i
by Edison and which would result in either, (a) plant modifications, (b) procedure revisions, or (c) changes in facility staffing requirements; or items perceived by Edison as prospective NRC requirements; or major tasks resulting from mandates of agencies other than the NRC. Also included are evaluations for major initiated issues not required by regulation, license conditions or orders.
Schedule C Edison initiated plant betterment projects.
The program reflects limited outage time, financial resources, and manpower resources, while at the same time implements those modifications deemed necessary for enhanced plant safety.
It provides for integration of all future identified work into one comprehensive schedule and has built-in mechanisms for changes to the schedule when new modifications are identified or when key program milestones cannot be achieved due to considerations beyond the control of Edison.
The IIS program is based on a priority determination to assist in l
maximizing the benefit derived from regulatory required capital i
projects. Since it is not always possible or beneficial to try to l
implement a large number of capital projects in a single outage, the program provides a mechanism for focusing attention on those projects of highest priority.
Schedule A dates may be modified only with prior NRC approval in accordance with existing NRC procedures. Changes in Schedule B dates require written notification to the NRC. Schedule C dates are provided !
for information to allow the NRC to gain perspective on the current backfit load and may be changed at Edison's discretion.
The IIS program requires that Edison 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.
Edison is required to update Schedules A, B, and C semi-annually and submit the revised schedules to the NRC.
In addition to updating schedules, Edison is required to:
]
o Summarize progress in implementing NRC requirements concerning plant modifications.
o Identify changes since the last report.
o Summarize the reasons for schedule changes associated with Schedules A and B.
o Indicate the expected percentage allocation of resources on Regulatory and Betterment projects for the next refueling / modification outage.
The First Edition of the IIS was sent to the NRC on November 15, 1989.
As required, it provided the Schedule A, B, and C items for the Cycle 6 Refueling Outage for SONGS 2 and Cycles 5 and 6 for SONGS 3.
Subsequent editions of the IIS (through the 12th Edition) have provided the required schedules through Cycles 9 for SONGS 2 and 3.
Regulatory project allocations for refueling outages have been steadily decreasing and are currently under 40% of resources. Regulatory projects which have been added to schedules since the initial IIS letter have not affected the priority rankings of projects. WARP has only been used once since inception of the IIS Plan. Normal Edison scheduling methods have been used for these new projects.
Their implementation schedules were established in separate correspondence, other than the IIS letter.
The bulk of the been Schedule C (betterment) projects found on recent IIS letters have projects which have had their worth determined by Edison and are under its control for scheduling purposes.
Examination of SONGS 2 and 3 operating history since inception of the license conditions further illustrates these points. Higher burnups, shorter refueling outages, fewer forced outages, and higher gross and net capacity factors are some of the reasons that fewer new Schedule A and B projects have been included in subsequent refueling outages. Most of the work that has been done during these outages has been restricted to required refueling and maintenance and that which Edison has determined to be betterment (Schedule C).
Consequently, the requirements of the license conditions are redundant to other mechanisms which are in place to respond, track, and implement regulatory projects.
Internal mechanisms for responding to NRC Rules and Orders, Notices of Violation, Generic Letters, Licensee Event Reports, etc., are more than adequate to ensure proper control over the
.l r
scheduling and implementation of new regulatory required projects generated from these documents. These internal mechanisms more than meet the intent of implementing capital modifications at SONGS 2 and 3 in a stable and controlled manner. Therefore, at this time, the IIS Program is unnecessary.
Retention of the license conditions is an unnecessary burden.
Cost savings realized from their deletion are estimated to result in a total present worth savings in excess of $100,000 for the two units over the lifetime of the plant. This savings is based on a $5,000 cost per semi-annual letter for the remaining seventeen years of the licenses for SONGS 2 and 3.
Reference 8 states that the NRC does not require licensees to incorporate integrated scheduling into operating licenses as a license condition and that those currently implementing an integrated schedule may withdraw from the program upon notifying the NRC. Additionally, the voluntary nature and intent of the license conditions as detailed in References 2, 7, and Section VII of the license conditions, would allow Edison to reinstate the IIS Plan in the future if it became prudent to do so. Therefore, this PCN requests deletion of the license conditions.
4.0 DISCUSSION OF CHANGES TO PCN-299:
PCN-299 implements the Technical Specification Improvement Project which incorporates the recommendations of NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants."
PCN-299 was submitted to the NRC for review on December 30, 1993. This proposed change does not affect that submittal.
5.0 SAFETY ANALYSIS:
The proposed change described above shall be deemed to involve a significant hazards consideration if there is any positive finding in any one of the following areas.
1.
Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?
Response: No The proposed change deletes an administrative means of tracking and scheduling NRC required plant modifications and license commitments.
It does not affect the plant configuration nor NRC mandated schedules for implementation of modifications.
Because the deletion of the license condition does not affect the plant configuration, no accident analyses are affected; therefore, the proposed change does not increase the probability or consequences of any previously evaluated accident.
2.
Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any previously evaluated?
Response: No The proposed change will not alter the configuration of the plant or its operation; therefore, the proposed change does not create a new or different kind of accident from any previously evaluated.
3.
Will operation of the facility in accordance with this proposed change involve a significant reduction in margin to safety?
Response: No The proposed change is administrative and does not affect any accident analyses or involve any modification to the plant configuration; therefore, the proposed change does not involve a reduction in a margin of safety.
6.0 SAFETY AND SIGNIFICANT HAZARDS DETERMINATION:
Based on the above Safety Analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change. Moreover, because this action does not involve a significant hazards consideration, it will also not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.
7.0 REFERENCES
1.
Letter, Mr. K. P. Baskin (Edison) to Mr. H. R. Denton (NRC) dated August 28, 1986 2.
Generic Letter 83-20 dated May 9, 1983;
Subject:
Integrated Scheduling for Implementation of Plant Modifications 3.
Letter, Mr. M. O. Medford (Edison) to Mr. G. W. Knighton (NRC) dated November 21, 1986 4.
Letter, Mr. M. O. Medford (Edison) to Document Control Desk (NRC) dated February 1, 1988;
Subject:
Integrated Implementation Schedule 5.
Letter, Mr. D. E. Hickman (NRC) to Mr. K. P. Baskin (Edison) dated May 15, 1989;
Subject:
Issuance of Amendment No. 72 to Facility Operating License No. NPF-10 and Amendment No. 60 to Facility Operating License No. NPF-15, San Onofre Nuclear Generating Station, Units 2 and 3 6.
Letter, Mr. K. P. Baskin (Edison) to Mr. H. R. Denton (NRC) dated September 2, 1983;
Subject:
Integrated Living Schedule Methodology 7.
Generic Letter 85-007 dated May 2, 1985;
Subject:
Implementation of Integrated Schedules for Plant Modifications 8.
Federal Register, Volume 57, No. 185 dated September 23, 1992;
Subject:
Integrated Schedules; Policy Statement 1
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o ATTACHMENT A EXISTING LICENSE CONDITIONS UNIT 2
Full Power' 4
Oualification of Auxiliary Feedwater ( AFW) Pumo Motor Bearinos (25)
By October 30, 1982, SCE shald submit a proposed hardware modification and schedule for implementation that will increase the reliability of the AFW motor-driven pumps in the event of a break in the high energy line feeding the steam-driven pump.
In the
- interim, prior to installation of a hardware modification acceptable to the NRC Staff, SCE shall perform an augmented in-service inspection of the steam line in accordance with SCE's letter of July 12, 1982.
(26)
INTEGRATED IMPLEMENTATION SCHEDULE The Southern California Edison Company (SCE) shall implement a plan for scheduling all capital modifications based on the attached Integrated Implementation Schedule Program Plan (the
" Plan").
The Plan shall be followed by the licensee beginning with (1) the effective date of this amendment.
Changes to completion dates for items identified in (2)
Schedules B and C of the Plan do not require a license Dates specified in Schedule A of the Plan amendment.
shall be changed only in accordance with applicable NRC procedures.
1
Attachment:
Integrated Implementation Schedule Program Plan JUL171989 AMENCf4ENT NO. 72
l ATTACHMENT INTEGRATED IMPLEMENTATION SCHEDULE PROGRAM PLAN SAN OWOFRE. NUCLEAR. GENERATING. STAT 10W,. UNITS 2. AND.3 I.
INTRODUCTION This document provides the methodology to be used in determining the l
4 implementation schedules of capital projects at San Onofre Units 2 and 3.
The program has as its goal the implementation of capital modifications I
,in a stable, controlled manner with the implementation of projects with the greatest potential for enhancing the safe operation of the unit generally given highest priority. The projects of regulatory origin will a
be ranked using the Westinghouse Analytical Ranking Process to i
specifically determine the relative potential safety contribution of each modification. The safety ranking will then be used as a primary criterion in scheduling the projects. For betterment projects the priority and schedule will be determined by the Plant Modification Review Committee. The Connittee consists of management representatives involved in many areas of plant operation and is the most effective means of determining implementation schedules for those projects necessary for continued or improved plant operation, maintenance, etc.
The program reflects limited outage time, financial and manpower resources, while at the same time implementing those modifications deemed necessary for enhanced plant safety. The plan provides for integration of all future identified work into one comprehensive schedule and has built-in mechanisms for changes to the schedule when new modifications are identified or when key program milestones cannot be achieved due to considerations beyond the control of SCE.
II.
SUMMARY
OF PRIORITY. DETERMINATION The Integrated Implementation Schedule is based on a priority determination to assist in maximizing the benefit derived from modifications. Since it is not alw'ays possible or beneficial to try to implement a large number of modifications in a single outage, the integrated schedule provides a mechanism for focusing attention on.those projects of highest priority.
Regulatory related projects will be ranked using the Westinghouse Analytical Ranking Process. This process was approved for San Onofre Unit 1 by the NRC in a letter from D. G. Eisenhut, to X. P. Baskin, SCE, dated November 16, 1983. SCE will use the same methodology for SONGS 2 and 3. A description i
of the Westinghouse process was submitted to the NRC by letter dated September 2,1983 from Xenneth P. Baskin to H. R. Denton.
JULl71989 MENCNENT W. 72
l
. Betterment projects do not always have a major direct safety impact and vary in their effect on operation, maintenance, ALARA, reliability,.
availability, etc. These projects also var requiring a small expenditure of resources.,y in magnitude from those to those requiring substantial resources and outage time.
In many instances, the implementation of a betterment project may be necessary on an expedited schedule due to.a anticipated negative impact on plant operation. Due to these and other factors, the betterment projects have their priority and schedule determined by SCE's Plant Modification Review Connittee. The Committee is incorporated into the. review cycle for approval of plant modifications by San Onofre Procedure 50123-XIX-3.D. This committee consists of SCE representatives from areas of plant operations and management.
In this way, special consideration is given to particular attributes of a betterment project that may make it imperative to implement on an expedited schedule.
III. SCHEDULING Once the projects are ranked they will be evaluated using normal scheduling methocs to determine how long they will take to implement.
The projects ranked highest will first be evaluated to determine whether they can be implemented during the next scheduled refueling outage.
Projects will continue to be selected from the top of the ranked lists and schedulev for the earliest outage in which implementation constraints of a normal refueling outage have not been exceeded. These schedules will then be separated into three lists as described below:
Schedule.A i
All items which have implementation dates required by NRC regulations, orders or license conditions.
Schedule B Regulatory items (of either generic or plant specific nature) identified by the NRC which have implementation dates committed to by)SCE and which would result in either (a) plint modifications, (b procedure revisions, or.(c) changes in facility staffing requirements; or items perceived by SCE as prospective NRC requirements; or major tasks resulting from mandates of agencies other than the NRC. Also included are evaluations for major initiated issues not required by regulation, license conditions or orders.
Schedule C SCE initiated plant betterment projects.
JULl71989 METENENT to. 72 m
. 1 Schedule A dates inay be modified only with prior NRC approval in accordance with existing NRC procedures. Changes in Schedule B dates require written notification to the NRC as described in Section Y below.
Schedule C dates are provided for information to allow the NRC to gain perspective on the scope of overall modifications and may be changed at.
SCE's discretion. Schedules A, B and C together provide the basis for assessing the overall effect of changes to schedules and serve as a departure point for discussiun between the NRC and SCE regarding such changes, as discussed below.
IV.
SCHEDULEMODIFICATIO_NS An important aspect of SCE's planning effort is the recognition that the schedule will need to be modified at times to reflect changes in regulatory requirements, to accommodate those activities that SCE finds necessary to improve plant efficiency and reliability, and to take into account delays resulting from events beyond SCE's control.
It is important that the procedure used by SCE 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 SCE be clearly defined, as discussed below.
Y.
SOUTHERN. CALIFORNIA EDISON. COMPANY. RESP 0HSIBILITIES The Integrated Implementation Schedule requires that SCE 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.
A.
periodic. Updating Southern California Edison will update Schedules A, B and C semi-annually and submit the revi' sed schedules to the NRC beginning six months following NRC approval of the Plan. 'In addition to updating the schedules, SCE will:
Sumarize progress in implementing NRC requirements concerning plant modifications.
Identify changes since the last report.
Sumarize the reasons for schedule changes associated with Schedules A and B.
- /
Senedules A, B and C will contain sufficient detail to identify those
~
plant capital modifications with completion dates keyed to fuel cycle outages. The schedules may.also contain specific dates (either calendar date or keyed to some other milestone) for major evaluations.
JULl71939 n e c e4r wo. 22
4-Indicate the expected percentage allocation of resources on Regulatory and Betterment projects for the next refueling /
modification outage.
B.
Chances to Schedules Changes to the schedules may arise from a variety of reasons, such as new work activities; modifications to the scope of scheduled work; problems in delivery, procurement, etc.; changes in NRC rules and regulations; or other NRC or SCE 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:
Determine the priority of the project, or changed priority, using the Westinghouse Analytical Ranking Process.
Schedule the new or changed item to avoid rescheduling other items already well underway, if it can be reasonably achieved.
Alter Schedule B and C items before Schedule A items.
Select a schedule for the new or changed item which will help maintain an optimum integrated program of work.
If a new Schedule A item is added, regardless of the results of the above ranking / scheduling process, the implementation schedule of the new item shall comply with applicable NRC regulations, orders, or license conditions unless a different schedule has been formally established in accordance with appropriate Coavnission procedures.
As noted above, no changes will be made to Schedule A without prior NRC approval. Should a change become necessary, it will only be proposed after SCE has determined that rescheduling of lower priority work either will not significantly assist in maintaining Schedule A without change, or that the safety, cost or schedule penalties from rescheduling lower priority work significantly outweigh the change in a Schedule A completion date.
SCE will inform the NRC Project Manager when serious consideration is given to requesting a change in Schedule A.
When SCE determines that a change in Schedule A is necessary, it will submit a written request for NRC approval in accordance with applicable procedures.
SCE will notify NRC in writing at least 30 days before adopting a planned delay for an item in Schedule B.
Such notification will also include the reasons for the delay and describe any compensatory actions indicated. The revised date proposed by SCE will go into effect AMEMMNT NO. 72 3
JULl71939
. unless NRC, in writing, requests further explanation or discussion concerning such change.
If NRC makes such a request, it will be made within 15 days of receipt of SCE'S written notification.
In this event, discussions will be initiated to promptly develop a schedule date which is mutually acceptable to SCE and the NRC Project Manager while considering overall program impact. The written notification by NRC will serve to extend the schedule date for the period of time requirec for such discussions.
If a new date is established in these discussions such date will supersede the date set forth in Schedule B.
The new date will be incorporated in a revised Schedule B in the next semi-annual schedule update submitted to NRC.
If a' new date cannot be established in these discussions, SCE changes in scheduled dates will be effective unless subsequently modified by NRC Order.
Work items in Schedule C may be rescheduled or work items may be acded to Schedule C by SCE without NRC notification. SCE will report changes to Schedule C items in its semi-annual update to be provided in accordance with Section V.A above. This schedule is provided for information purposes only and is intended to provide the NRC 4 better understanding of the unit's overall modifications program.
VI. N2C REVIEW As pointed out in Section V.B above, changes to the schedules are inevitable, Actions required by the NRC are discussed below:
A.
Southern California. Edison. Originated. Changes 1.
Upon receipt from SCE of a request for modification of Schedule A, NRC will act promptly (consistent with resource availability and priority of other work) to act on the request in accordance with applicable procedures.
2.
If the request for a modification of Schedule A is denied, the NRC shall promptly inform SCE and provide 'the reasons for denial.
3.
NRC consideration of SCE changes in non-Schedule A items is covered by V.B above.
B.
HRC Originated. Changes (Schedule. A)
It is recognized that formal NRC regulatory actions ma (1) impose a new regulatory requirement with a fixed date or (2) y:
establish a firm date for a previously identified regulatory requirement.
In taking any such action, the NRC, to the extent consistent with this overall regulatory responsibilities and, unless public health, ANNUHrf NO. 72 JULl71939
4 J
l 6-safety, or interest require otherwise, will take into account the impact of such action on SCE's ability to cceplete effectively the items on Schedules A, B and C and, in consultation with SCE, will try to minimize such impact. Although.'any formal regulatory action taken by the NRC will be effective in accordance with its terms l
without inclusion in Schedule A, the NRC.and SCE. recognize the desirability of incorporating such action into Schedule A, particularly in order to incorporate at the same tire any other appropriate changes in the total integrated schedule program.
Accordingly, once such formal regulatory action is taken (or earlier, if practicable), the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated l
schedule program which would most effectively accomodate such require-ments. Any resulting changes in items in Schedule A will be submitted to the NRC for review in accordance with established procedures, and, if approved by the Comission, will thereupon be reflected in a revised i
Schedule A submitted by SCE. SCE will inform the NRC of any resulting J
changes in Schedule B in accordance with Section V above.
C.
New NRC Issues.(Schedule.B)
The NRC ray, from time to time, identify new regulatory issues which may result in (a) plant inodifications, (b) procedure revision or development, or (c) changes in facility staffing requirements.
For issues on which the NRC requests scheduling information, these issues may be included in Schedule B in accordance with the date comitment developed in discussion between SCE and the NRC staff.
As for the case of HRC originated changes to Schedule A items, the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accornrnodate such issues. Any resulting changes in integrated program schedules will thereupon be reflected in a revised Schedule B submitted by SCE.
VII. M00!FICATIONS.TO.THE plan The licensees and the NRC recognize that the Plan itself may require future modifications. Accordingly, SCE will draft' proposed modifications and submit a license amendment application for approval of the proposed changes. The changes, if approved, will be made effective upon amendment issuance by the NRC.
JUll71939 NGITUT NO. 72 e
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I i
I ATTACHMENT B EXISTING LICENSE CONDITIONS UNIT 3
e Full Power 3
t (25) Correction of CPC Software Error At the first outage of sufficient duration (7 days in Mode 5) after February 2, 1984, SCE shall correct the software error in the Core Protection Calculators discussed in the SCE letters dated March 7, 1893 and July 22, 1983.
t l
(26) Until the first refueling outage, SCE shall provide a monthly report describing any occurrences resulting in the degradation
~
(including, but not limited to component failures; maintenance errors, and operator errors) of the auxiliary feedwater system.
l The report shall identify the cause of such occurrences. The report does not relieve the licensee from any existing requirements for Licensee Event Reports (LERs).
(27)
INTEGRATED IMPLEMENTATION SCHEOULE The Southern California Edison Company (SCE) shall implement a plan for scheduling all capital modifications based on the attached Integrated Implementation Schedule Program Plan (the l
" Plan").
(1)
The Plan shall be followed by the licensee beginning with the effective date of this amendment.
(2)
Changes to completion dates for items identified.in Schedules 8 and C of the Plan do not require a license amendment. Dates specified in Schedule A of the Plan shall be changed only in accordance with applicable NRC procedures.
4.
In accordance with the. Memorandum and Order (Ruling on Off-site Medical Services Issue) ASLBP 78-365-010L dated August 12, 1983.
Paragraph 2.C(18)c of Amendment No. 4 is hereby deleted.
Attachment:
Integrated Implementation Schedule Program Plan jut 171939 7
MiENDMENT NO. 60
t 1
ATTACHMENT INTEGRATED IMPLEMENTATION SCHEDULE PROGRAM PLAN SAH ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 i
I.
INTRODUCTION This document provides the methodology to be used in determining the,
implementation sche ~cules of ~ capital projects at San Onofre. Units 2' and 3..
~
The program has as kts goal the implementation of capital modifications in a stable, controlled manner with the implementation of projects with the greatest potential for enhancing the safe operation of the unit generally given highest priority.
The projects of regulatory origin will be ranked using the Westinghouse Analytical Ranking Process to specifically determine the relative potential safety contribution of each modif.ication.
The safety ranking will then be used as a primary criterion in scheduling the projects.
For betterment projects the priority and schedule will be determined by the Plant Hodification Review Committee. The Co.uittee consists of management representatives involved in many areas of plant operation and is the most effective means of determining implementation schedules for those projects necessary for continued or improved plant operation, maintenance, etc.
The program reflects limited outage time, financial and manpower resources, while at the same time implementing those modifications deemed necessary for enhanced plant safety. The plan provides for integration of all future identified work into one comprehensive schedule and has built-in mechanisms for changes to the schedule when new modifications i
are identified or when key program milestones cannot be achieved due to considerations beyond the control of SCE.
II. SUMARY OF PRIORITY DETERMINATION The Integrated Implementation Schedule is based on a priority 9
determination to assist in maximizing the benefit derived from modifications. Since it is not always possible or beneficial to try to 4
implement a large nuster of modifications in a single outage, the integrated schedule provides a mechanism for focusing attention on those projects of highest priority.
Regulatory related projects will be ranked using the Westinghouse Ana'lytical Ranking Process. This process was approved for San Onofre Unit i by-the HRC'in a letter from D. G. Eisenhut, to K. P. Baskin, SCE,-dated Noves6er 16, 1983.- SCE will use the same authodology for SONGS 2 and 3. A description of the Westinghouse process was submitted to the NRC by letter dated Septester 2,1983 from Xe.,neth P. Baskin to H. R. Denton.
so Menerr NO. 60 JUL17 E39
.=w
. 8etterment projects do not always have a major direct safety impact and vary in their effect on operation, maintenance, ALARA, reliability, availability, etc. These projects also vary in magnitude from those requiring a small expenditure of resources to those. requiring substantial resources and outage time.
In many instances, the implementatica of a betterment project may be necessary on an expedited schedule due to a anticipated negative impact on plant operation. Due to these and other factors, the betterment projects have their priority and schedule determined by SCE's Plant Modification Review Connittee. The Committee is incorporated into the review cycle for approval of plant modifications by San Onofre Procedure 50123-XIX-3.0. This cocnittee consists of SCE representatives from areas of plant operations and management.
In this way, special consiceration is given to particular attributes of a betterment project that may make it imperative to implement on an expedited schedule.
III. SCHEDULING Once the projects sre ranked they will be evaluated using normal scheduling nethods to determine how long they will take to implement.
The projects ranked highest will first be evaluated to determine whether they can be implemented during the next scheduled refueling outage.
projects will continue to be selected from the top of the ranked lists and scheculed for the earliest outage in which implementation constraints of a normal refueling outage have not been exceeded. These schedules
~
will then be separated into three lists as described belo'w:
Schedule A All items which have implementation dates required by HRC regulations, orders or license conditions.
Schedule 8 Regulatory items (of either generic or plant specific nature) identified by the NRC which have implementation dates committed to by SCE and which would result in either (4) plant modifications, (b) procedure revisions, or (c) changes in facility staffing requirements; or items perceived by SCE as, prospective'NRC requirements; or major tasks resulting from mandates of agencies other than the NRC. Also included are evaluations for najor initiated issues not required by regulation, license conditions or orders.
Schedule C SCE initiated plant betterment pr. ects.
JUL17 h'39 M'WEMNT NO. 60
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l.
3 l.:
I i
Schedule A dates r.ay be modified only with prior NRC approval in accordance with existing NRC procedures. Changes in Schedule B dates require written notification to the NRC as described in Section V below. -
i Schedule C dates are provided for 'information to allow the NRC to gain perspective on the scope of overall modifications and may be changed at SCE's discretion.
1 Schedules A, B and C together provide the basis for j
assessing the overall effect of changes to schedules and serve as a departure point for discussion between the NRC and SCE regarding such j
changes, as discussed below.
IV. SCHEDULE MODIFICATIONS 1
i An important aspect of SCE's planning effort is the recognition that the schedule will need to be modified at times to reflect changes in regulatory requirements, to accosciodate those' activities that SCE finds necessary to improve plant efficiency and reliability, and to take into account delays resulting from events beyond SCE's control.
It'is i
important that the procedure used by SCE for changing the schedules be documented. */ In addition the NRC must play a role in the oversight of the scheduling process an,d 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 SCE be clearly defined, as discussed below.
Y.
SOUTHERN CALIFORNIA EDISON COMPANY Resp 0NSIBILITIES The' Integrated Implementation Schedule requires that SCE 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.
A.
periodic Updating Southern California Edison will update Schedules A, B and C semi-annually and submit the'revtsed schedules to the NRC beginning six months following NRC approval of the Plan.
In addition to updating the schedules, SCE will:
Summarize progress in implementing NRC requirements concerning' plant modifications.
~
i Identify changes since the last report.
- Sussnarize the reasons for schedule changes. associated with
' Schedules A and B.
'/
schedules A, B and C will contain sufficient detail to identify those plant capital modifications with completion dates keyed to fuel cycle The schedules may also contain specific dates (either calendar outages.
date or keyed to some other milestone) for major evaluations.
JULl710%
m-m. so
-. -. -.. - -. -. ~. -. - -.. - - _ _ -.
3 a
I A
l Indicate the expected percentage allocation of resources on Regulatory and Betterment projects for the next refueling /
modification outage.
B.
Changes t'o Schedules Changes to the schedules may arise from a variety of reasons, such as new work activities; modifications to the scope of scheduled work; problems in delivery, procurement, etc.; changes In NRC rules and regulations; or other NRC or SCE actions.
Where it is necessary to add a new work ites or to change the schedule for an item, the following general guidance will be utilized to the extent appropriate:
Detamine the priority of the project, or changed priority, using the Westinghouse Analytical Ranking Process.
Schedule the new or changed item to avoid rescheduling other items already well underway, if it can be reasonably achieved.
Alter Schedule B and C items before Schedule A items.
Select a schedule for the new or changed item which will help l
maintain an optimum integrated program of work.
If a new Schedule A item is added, regardless of the results of the above ranking / scheduling process, the implementation schedule of the i
new item shall comply with applicable NRC regulations, oroers, or license conditions unless a different schedule has been formally established in accordance with appropriate Consission procedures.
I i
As noted above, no changes will be made to Schedule A without prior NRC approval. Should a change become necessary, it will only be proposed after SCE has determined that rescheduling of lower priority work either will not significantly assist in maintaining Schedule A without change, or that the safety, cost or schedule 1
penalties from rescheduling lower priority work significantly outweigh the change in a Schedule A ccmpletion date.
SCE will inform the NRC Project Manager when serious consideration 1s given to requesting a change in Schedule A.
When SCE detemines that a change in Schedule A is necessary, it will submit a written request for NRC approval in accordance with applicable procedures.
J SCE will notify NRC in writing at least 30 days before adopting a planned delay for an itee in Schedule B.
Such notification will also 1
include the reasons for the delay and describe any compensatory actions indicated. The revised date proposed by SCE will go into effect JULP/W39
^
AMENTENT NO. 60 l
e i
unless HRC, in writing, requests further explanation or discussion concerning such change.
If HRC makes such a request, it will be made within 15 days of receipt of SCE'S written notification.
In this event, discussions will be initiated to promptly develop a i
schedule date which is mutually acceptable to SCE and the NRC Project Manager while considering overall progras~ impact. The written notification by NRC will serve to extend the schedule date for the period of time required for such discussions. If a new date is established in these discussions such date will supersede the date set forth in Schedule 8.
The new date will be incorporated in a revised Schedule B in the next semi-annual schedule update submitted to NRC.
If a new date cannot be established in these discussions, SCE changes in scheduled dates will be effective unless subsequently codified by HRC Order.
i Work items in Schedule C may be rescheduled or work' items may be added to Schedule C by SCE without NRC notification. SCE will report changes to Schedule C items in its semi-annual update to be provided in accordance with Section V.A above. This schedule is e
i provided for information purposes only and is intended to provide the NRC a better understanding of the unit's overall modifications progrsm.
VI. NRC REVIEW i
)
As pointed out in.Section V.B above, changes to the schedules are 4
inevitable., Actions required by the NRC are oiscussed below:
A.
Southern California Edison Originated Changes 1.
Upon receipt from SCE of a request for modification of Schedule A. NRC will act promptly (consistent with resource availability ano priority of other work) to act on the request in accordance j
with applicable procedures.
1 2.
If the request for a modification 'of Schedule A is denied, the NRC shall promptly inform SCE and provide the reasons for dental.
2 3.
MRC consideration of SCE changes in non-Schedule A items is covered by V.S above.
)
8.
MRC 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 fira date for a previously identic ed regulatory requirement.
In taking any such action, the NRC, to the wxtent consistent with this overall regulatory responsibilities and, unless public health, JUL17W
~
AMENEfENT to. 60 i
l
' safety, or interest require otherwise, will take into account the impact of such action on SCE's ability to complete effectively the items on Schedules A, B and C and, in consultation with SCE, will try to minimize such impact. Although ary formal regulatory action i
taken by the NRC will be effective in accordance with its terms without inclusion in Schedule A, the NRC and SCE recognize the J
desirability of incorporating such action into Schedule A, particularly in order to incorporate at the same time any other 4
appropriate changes in the total integrated schedule program.
4 Accordingly, unce such formal regulatory action is taken (or earlier, if practicable), the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively acconnodate such require-ments. Any resulting changes in items in Schedule A will be submitted to the NRC for review in accordance with established procedures, and, if approved by the Comission, will thereupon be reflected in a revised l
Schedule A submitted by SCE. SCE will inform the NRC of any resulting changes in Schedule B in accordance with Section Y above.
C.
New NRC Issues (Schedule B)
The NRC may, from time to time, identify new regulatory issues whic'h may result in (a) plant modifications, (b) procedure revision or development, or (c) changes in facility staffing requirements.
For issues on which the NRC requests scheduling information, these issues may be included in Schedule B in accordance with the date comitment develuped in discussion between SCE and the NRC staff.
As for the case of HRC originated changes to Schedule A items, the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accennodate such issues. Any resulting changes in integrated program schedules will thereupon be reflected in a revised Schedule B submitted by SCE.
VII. MODIFICATIONS TO THE PLAN The licensees and the NRC recognize that the Plan itself may require future modifications. Accordingly, SCE will draf t proposed modifications and submit a license amendment application for approval of the proposed changes. The changes, if approved, will be made effective upon amendment issuance by the NRC.
JULl?B09 N'imCM!NT NO. 60
_a_
S i
s.
I I
1 i
l 1
1 1
ATTACHMENT C PROPOSED LICENSE CONDITIONS UNIT 2 1
1 l
Full Power Oualification of Auxiliary Feedwater ( AFW) Pumo Hotor Bearinet (25)
By October 30, 1982, SCE shald submit a proposed hardware modification and schedule for implementation that will increase the reliability of the AFW motor-driven pumps in the event of a break in the high energy line feeding the steam-driven pump.
In the
- interim, prior to installation of a hardware modification acceptable to the NRC Staff, SCE shall perform an augmented in-service inspection of the steam line in accordance with SCE's letter of July 12, 1982.
(26)N INTEGRATED IMPLEMENTATION SCHEDULE shall implement thernCaliforniaEdisonCompany(SCE)[onsbasedonthe The scheduling all capital modific3t a plan rated Implementation Sche me Program Plan (the attached In
" Plan"),
i (1)
The Plan shall lowed by'the licensee beginning with the effective date th ( amendment.
l date s for items identified in (2)
Changes to completicthe Plan dNot require a license s
Schedules 8 and C o Dates specified in ScRedule A of the Plan amendment.
shall be change only in accordance wi applicable NRC procedures.
Attachment:
Integrated Implementation edule Program Plan J'UL171989 4
AMENCHENT NO. 72
ATTACHMENT INTEGRATED IMPLEMENTATION SCHEDULE PROGRAM PLAN SAM. NOFRE. NUCLEAR. GENERATING. STATION,. UNITS.2. AND.3 INTRODUCTION s the methodology to be used in deten/
This document provi ntning the implementation schedu s of capital projects at San Ono fe Units 2 and 3.
The program has as its go 1 the implementation of cap tal modifications
.in a stable, controlled ma er with the implementat 6n of projects with the greatest potential for e ancing the safe oper tion of the unit generally given highest priori The projects o regulatory origin will be ranked using the Westinghouse nalytical Ran)dng process to specifically determine the relativ potentialgafetycontributionofeach modification. The safety ranking w il then be used as a primary criterion in scheduling the projects. Forbett6pntJrojectsthepriorityand schedule will be determined by the Plantjodification Review Connittee. The Committee consists of management representatives involved in many areas of plant operation and is the most effectivi heans of determining implementation schedules for those projects necessary for continued or improved plant operation, maintenance, etc.
The program reflects limited outage time, financ al and manpower resources, while at the same time im e modifications deemed necessaryforenhancedplantsafeIy.plementingth The plan prov des for integration of all future identified work in chedule and has built-in mechanisms for changes'to one comprehensive to the schedule when n modifications are identified or when key pr gram milestones cannot be hieved due to considerations beyond the c3 trol of SCE.
II. SU9tARY OF PRIORITY.0ETERS NATION i
TheIntegratedImplemektationScheduleisbasedonapriority determination to assi in maximizing the benefit derived from modifications. Sinc it is not alw'ays possible or beneficial to try imple: rent a large n er of modifications in a single outage, the integrated schedu 4 provides a mechanism for focusing attention on.those projects of high t priority.
Regulatory rel ted projects will be ranked using the Westinghouse Analytical Ranking Proce s.
This process was approved for San Onofre Unit 1 by the NRC in a let er from D. G. Eisenhut, to X. P. Baskin, SCE, dated November 16, 1983.
CE will use the same methodology for SONGS 2 and 3. A description of the West ghouse process was submitted to the NRC by letter dated September 2; 1983 from Kenneth P. Baskin to H. R. Denton.
JULl71989 MENCMENT NO. 72
. s Bette nt projects do not always have a major direct safety impact and vary in eir effect on operation, maintenance, ALARA, reliability, These projects also var availabili
, etc.
11 expenditure of resources.y in magnitude from those to those requiring. substantial requiring a resources and tage time.
In many instances, the implementation of a betterment proje t may be necessary on an expedited schedule due to.a anticipated negat e impact on plant operation. Due to these and nther factors, the bette nt projects have their priority and schedule determined by SCE's nt Modification Review Comittee. The Comittee is incorporated into the view cycle for approval of plant modifications by San Onofre Procedure 501
-XIX-3.0.
This comittee~ consists of SCE representatives from areas f plant operations and managernent.
In 1!his J
way, special consideration i given to particular attributes of a betterment project tnat may ma it imperative to implement on an expedited schedule.
III. SCHEDULING Once the projects are ranked they will evaluated using normal scheduling methocs to determine how long ey will take to implement.
The projects ranked highest will first'be e luated to detennine whether they can be implemented during the next sche led refueling outage.
Projects will continue to be selecte'd from the p of the ranked lists and scheduled for the earliest outage in which in lementation constraints i
of a normal refueling outage have'not been exceede These schedules will then be separated into three lists as described elow:
Schedule.A All items which have m lementation dates required by C regulations, orders or license conditions.
/
Schedule B
/
/
Regulatory items (of either generic or plant specific nature) j identified by the NRC which have implementation dates comitted a by SCE and which would result in either (a) pla'nt modifications, (b) procedure revisions, or.(c) changes in facility staffing r
requirements; or items perceived by SCE as prospective NRC requirem nts; or major tasks resulting from mandates of agencies other t n the NRC. Also included are evaluations for major initia d issues not required by regulation, license conditions or order.
Sch ule C SCE initiated plant bettennent projects.
JUll71989 MODENT No. 72
~
Sch dule A dates may be modified only with prior NRC approval in rdance I
with xisting NRC procedures. Changes in Schedule B dates requ're written notif tion to the NRC as described in Section Y below.
Sc ule dates are provided for information to allow the RC to gain per ective n the scope of overall modifications and may e changed at.
e SCE's iscret n.
Schedules A, 8 and C together provide the basis for assessi the o rail effect of changes to schedules an serve as a departure oint r discussiun between the NRC and SC regarding such changes, as iscus d below.
IV. SCHEDULE MODIFl TIONS An important aspect f SCE planning effort is e recognition that the schedule will need to e mod ied at times to r flect changes in regulatory requirements to ac omodate those ctivities that SCE finds necessary to improve plan effi ency and rel ability, and to take into account delays resulting fr eve ts beyond CE's control.
It is important that the procedure ed SCE fo changing the schedules be documented. ?/ In addition, th NR must lay a role in the oversight of the scheduling process and mus i fa t, judge the acceptability of proposed date changes in Schedule A A ordingly, it is important that the NRC's role, and the interaction te the NRC and SCE be clearly defined, as discussed below.
4 i
V.
SOUTHERN. CALIFORNIA EDISON. COMPANY.R PO IBILI ES st\\ha The Integrated Implementation Sche le requi SCE monitor the progress of the work undertaken, nage its ac ivitie to maintain the schedule, and act promptly to ta necessary act ns w n a schedule change is needed.
A.
Periodic. Updating Southern California E son will update Schedules A, and C semi-annually and su t the revised schedules to the RC beginning i
six months following RC approval of the Plan. 'In addi on to updating the sched es, SCE will:
Sumarizb progress in implementing NRC requirements conc ning plant modifications.
Identify changes since the last report.
3 Sumarize the reasons for schedule changes associated with Schedules A and B.
/
- /
5cnedules A, B and C will contain sufficient detail to identify those
~
plant ca ital modifications with completion dates keyed to fuel cycle outages. The schedules may.also contain specific dates (either calendar 1
date or keyed to some other milestone) for major evaluations.
4 i
JULl7I939 mm m. n 9
3 s.
1 j 1 i
l Indicate the expected percentage allocation of sources on j
Regulatory and Betterment projects for the nex refueling /
l modification outage.
B.
Change to. Schedules
)
Changes t the ahedules may arise from a var ety of reasons, such as new wor,u.etviiies; modifications to the scope of scheduled work; prob 1. 4 fn s elivery, procurement, et.; changes in NRC rules and regulatio s; or other NRC or SCE actio s.
Where it is nec sary to add a new work tem or to change the schedule for an i em, the following ge ral guidance will be utilized to the ex nt appropriate:
Determine the pr rity of the reject, or changed priority, using the Westingh use Analyt cal Ranking Process.
Schedule the new or c ange item to avoid rescheduling other items already well und
, if it can be reasonably achieved.
Alter Schedule B and C s before Schedule A items.
Select a schedule for he ne or changed item which will help maintain an optimum tegrate program of work.
If a new Schedule A it is added, r ardless of the results of the above ranking /scheduli g process, the r@lementation schedule of the new item shall comply with applicable N regulations, orders, or license conditions u less a different se dule has been formally established in acco dance with appropriate ommission procedures.
l As noted above, changes will be made to Se dule A without prior NRC approval.
ould a change become necessa it will only be proposed after CE has determined that reschedul g of lower priority work either will not significantly assis in maintaining Schedule A w thout change, or that the safety, cost r schedule penalties f om rescheduling lower priority work sign icantly outweigh e change in a Schedule A completion date.
SCE wil inform the NRC project Manager when serious cons eration is giv to requesting a change in Schedule A.
When SCE de ermines that change in Schedule A is necessary, it will submit a w tten requ st for NRC approval in accordance with applicable proced es.
SC will notify NRC in writing at least 30 days before adopting p nned delay for an item in Schedule B.
Such notification will a so i
lude the reasons for the delay and describe any compensatory act ns 1 icated. The revised date proposed by SCE will go into effect AMENDHT NO. 72 s
JULl71939 tH 6"e9
O
. )
unless NRC, in writing, requests further explanation or discussion concerning such change.
If NRC makes such a request, it will be
,ade within 15 days of receipt of SCE'S written notification.
n t is event, discussions will be initiated to p'romptly develop sc dule date which is mutually acceptable to SCE and the N Pro] ct Manager while considering overall program impact.
he writt notification by HRC will serve to extend the sc dule date for th period of time requireo for such discussions.
f a new date is estab ished in these discussions such date will s ersede the date set rth in Schedule B.
The new date will b incorporated in a revised S edule B in the next semi-annual sche le update submitted to RC.
If a' new date cannot be esta ished in these discussions, 5 changes 1n scheduled dates wi i be effective unless subsequently mo fied by NRC Order.
Work items in Sched le C may be reschedul d or work items may be aoded to Schedule C b SCE without NRC tification. SCE will report changes to Sche le C items in ts semi-annual update to be provided in accordance w th Section
.A above. This schedule is provided for information p rposes o y and is intended to provide the NRC a better understand g of ht unit's overall modifications program.
VI. NRC REVIEW As pointed out in Section V.B a ve, cha es to the schedules are inevitable, Actions required y the NRC e discussed below:
A.
Southern California.Ed on. Originated.C oges 1.
Upon receipt fr m SCE of a request fo modification of Schedule A, NRC will a promptly (consistent w h resource availability and priority of other work) to act on th request in accordance with appli ble procedures.
2.
If the r quest for a modification of Schedule is denied, the
]
NRC sh 1 promptly inform SCE and provide 'the asons for denia.
3.
NR consideration of SCE changes in non-Schedule A tems is c ered by V.B above.
B.
NRC riqinated. Changes (Schedule. A) is recognized that formal NRC regulatory actions ma (1) impose I new regulatory requirement with a fixed date or (2) y:establish a irm date for a previously identified regulatory requirement.
In taking any such action, the NRC, to the extent consistent with this overall regulatory responsibilities and, unless public health, AMEIDDrr NO. 72 JULl?1939
-.m
! s ety, or interest require otherwise, will take into account the imp t of such action on SCE's ability to complete effectively the items on Schedules A, B and C and, in consultation with
~, will E
try to inimize such impact. Althoughlany fonnal regu tory action taken by he NRC will be effective in accordance wit its terms without in lusion in Schedule A, the NRC.and SCE.re ognize the desirabilit of incorporating such action into Sc dule A, particularly order to incorporate at the same time any other appropriate cha es in the total integrated sc dule program.
Accordingly, one such formal regulatory acti is taken (or earlier, if practi ble), the NRC will provi e SCE a reasonable opportunity to prop e overall changes in e total integrated schedule program whic would most effecti ely acconmodate such require-ments. Any resulting anges in items Schedule A will be submitted to the NRC for review in ccordance wi established procedures, and, if approved by the Comis on, will t ereupon be reflected in a revised Schedule A submitted by SCE SCE w 1 inform the NRC of any resulting changes in Schedule B in acc danc with Section V above.
C.
New WRC Issues.(Schedule.B)
)
The NRC may, from time to ti
, ide tify new regulatory issues which may result in (a) plant mo fication, (b) procedure revision or development, or (c) chang in facili staffing requirements.
For issues on which the C reqeests s eduling information, these issues may be included n Schedule B in ccordance with the date cocnitment developed discussico betwe SCE and the NF.C reaff.
As for the case of N originated changes o Schedule A items, the NRC will provide SC a reasonable opportuni to propose overall changes in the to 1 integrated schedule pro am which would most 4
effectively acco date such issues. Any res ting changes in integrated prog am schedules will thereupon be eflected in a revised Sched e B submitted by SCE.
VII. MODIFICATIONS.TO HE. plan The licensees nd the NRC recognize that the Plan itself may quire future modif cations. Accordingly, SCE will draft ~ proposed mod cations and submit license amendment application for approval of the proposed changes.
he changes, if approved, will be made effective upon amehdment issuanc by the NRC.
JUL171939 AMENEM2rf NO. 72
O 4
6 3
9 l
ATTACHMENT D PROPOSED LICENSE CONDITIONS UNIT 3
Full Power (25)
Correction of CPC Software Error At the first outage of sufficient duration (7 days in Mode 5) after February 2,1984, SCE shall correc.t the software error in the Core Protection Calculators discussed in the SCE letters dated March 7, 1893 and July 22, 1983.
(26) Until the first refueling outage, SCE shall provide a monthly report describing any occurrences resulting in the degradation (including, but not limited to component failures; maintenance errors, and operator errors) of the auxiliary feedwater system.
The report shall identify the cause of such occurrences. The report does not relieve the licensee from any existing requirements for Licensee Event Reports (LERs).
)
INTEGRATED IMPLEMENTATION SCHEDULE e Southern California Edison Company (SCE) shall implement a p an for scheduling all capital modifications based on the attac d Integrated Implementation Sche le Program Plan (the
" Plan').
(1)
The Pla hall be followed ethe licensee beginning with the effect e date of t s amendment.
(2)
Changes to comp t n dates for items identified.in
~
Schedules 8 and C the Plan do not require a license amendment. Dat /spe ied in Schedule A of the Plan shall be chan d'only in cordance with applicable NRC procedures.
4.
In accordance with
'e. Memorandum. and Orde Ruling on Off-site Medical Services ue) ASLBP 78-365 010L date August 12, 1983.
Paragraph 2.C(18 of Amendment No. 4 is hereby de ted.
Attachment:
Integrated Implemen ation Schedule Program Plan jut 171939 AMENINENT NO. 60
ATTACHMENT INTEGRATED IMPLEMENTATION SCHEDULE PROGRAM PLAN SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1.
INTR UCTION This doc nt provides the methodology to be used in d ermining the..
implementa on schedules of ~ capital projects a.t San 0 fre, Units 2 an'd 3.
The program ha as its goal the implementation of c ital modifications in a stable, con lied manner with the implementa on of projects with the greatest poten tal for enhancing the safe ope ation of the unit generally given hig st priority.
The projects f regulatory origin will be ranked using the tinghouse Analytical Ran ing Process to specifically determine he relative potential afety contribution of each modif.ication. The safet ranking will then b used as a primary criterion j
in scheduling the projects. For betterment rojects the priority and schedule will be determined the Plant M ification Review Committee. The Cosmittee consists of manageme represen tives involved in many areas of plant operation and is the most fectiv means of determining implementation schecules for those projects neces ry or continued or improved plant operation, maintenance, etc.
The program reflects limited outage ime, financial and manpower resources, while at the same time i piement g those modifications deemed necessary for enhanced plant safet. The pla provides for integration of all future identified work int one comprehe sive schedule and has i
built-in mechanisms for changes the schedule en new modifications are identified or when key prog am milestones cann be achieved due to considerations beyond the cont 1 of SCE.
II. SlM4ARY OF PRIORITY DETERMINA ION The Integrated Implementati n Schedule is based on a priori determination to assist in maximizing the benefit derived fro modifications. Since it s not always possible or beneficial t try to implement a large nuster of modifications in a single outage, the in~tegrated schedule pro ides a mechanism for focusing attention on ose projects of highest pr'ority.
Regulatory related p Jects will be ranked using the Westinghouse Ana'lytica \\
Ranking Process.
Th s process was approved for San Onofre. Unit I by-the NRC~ in a letter f D..G. Eisenhut, to K. P. Baskin, SCE.-dated November 16, 1983'. SCE wil use the same methodology for SONGS 2 and 3. A description of the Westinghou e process was submitted to the NRC by letter dated Septerter 2,198 from Xer.neth P. Baskin to H. R. Denton.
AME1 DENT NO. 60 JUL17 E39 46 as 6
- - -. -~. - -.. - - -... -..
,s e
' 8etterv.ent projects do not always have a major direct safetyf mpact and i
vary in their effect on operation, maintenance, ALARA, real ability, availability, etc. These projects also vary in magnitud from those equiring a small expenditure of resources to those.re iring substantial ources and outage time.
In many instances, the i ementation of a bet rment project may be necessary on an expedited chedule due to a antic ated negative impact on plant operation. D to these and other factors, the bettennent projects have their prior ty and schedule detennine by SCE's Plant Modification Review C ittee. The Committee is incorporate into the review cycle for approva of plant modifications by San Onofre Pr cedure 50123-XIX-3.D. This cc ittee consists of SCE representative from areas of plant operati s and management.
In this way, special con ceration is given to par icular attributes of a betterment project hat rnay make it imper tive to implement on an expedited schedule.
III. SCHEDULING Once the projects are ranke they ill be evaluated using normal scheduling methods to dutorm1 eh long they will take to implement.
The projects ranked highest wi first be evaluated to determine whether they can be irmlemented during next scheduled refueling outage.
Projects will continue to be ele ed from the top of the ranked lists and scheculed for the earlie t outa in which implementation constraints of a nonnal refueling outag have not een exceeded. These schedules
~
will then be separated int three lists as described belo'w:
Schedule A All items which p ve implementation dates equired by NRC regulations, orders or licen e conditions.
Schedule 8 Regulatory tems (of either generic or plant speci cnature) identified by the NRC which have implementation date committed to which would result in eJther (a) plant modi cations, by)SCE an ure revisions, or (c) changes in f acility staf g
(b proc requir nts; or items perceived by SCE as, prospective NRC requi nts; or major tasks resulting from mandates of agene s other than the NRC. Also included are evaluations for major
)
ini ated issues not required by regulation, license conditions or oC rs.
5,hedule C CE initiated plant bettennent pr. ects.
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Schedule A dates r.ay be modified only with prior NRC approval in accordance with existing NRC procedures. Changes in Schedule B dates require written notification to the NRC as described in Section V below. -
5 edule C dates are provided for 'information to allow the N C to gain per ective on the scope of overall modifications and may b changed at SCE's iscretion. Schedules A, B and C together provide basis for assess the overall effect of changes to schedules and erve as a departu oint for discussion between the NRC and SCE r garding such changes, a discussed below.
IV. S_CHEDULE MODI CATIONS An important aspe t of SCE's planning effort is t recognition that the schedule will need o be modified at times to re ect changes in regulatory requireme s, to acconnadate those a tivities that SCE finds necessary to improve p ant efficiency and reli ility, and to take into account delays resultin, from events beyond S E's control.
It'is important that the proced e used by SCE for changing the schedules be documented. */ In addition the NRC must ay a role in the oversight I
of the scheduling process an must, in fa
, judge the acceptability of proposed date changes in Sch le A.
Ac ordingly, it is important that the NRC's role, and the interac on be n the NRC and SCE be clearly defined, as discussed below.
Y.
SOUTHERN CALIFORNIA EDISON COMPANY p0NSIBILITIES The' Integrated Implementation Sch ule r utres that SCE monitor the progress of the work undertaken, nage i activities to maintain the schedule, and act promptly to t a necessa actions when a schedule change is needed.
A.
periodic Updating Southern California E ison will update Schedules
, B and C semi-annually and su mit the revtsed schedules to e NRC beginning
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s1x months followin NRC approval of the Plan.
In dition to updating the sched les, SCE will:
Summarize p gress in implementing NRC requirements oncerning' plant modi ications.
Identify changes since the last report. '
Susmar e the reasons for schedule changes associated with Sched es A and B.
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Schedules A, B and C will contain sufficient detail to identify those
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plant capital modifications with completion dates keyed to fuel cycle outages. The schedules may also contain specific dates (either calendar date or keyed to some other milestone) for major evaluations.
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a
' 4 Indicate the expected percentage allocation of resources on Regulatory and Betterment projects for the next refueling /
modification outage.
8.
hanges to Schedules Cha es to the schedules may arise from a variety of easons, such as n work activities; modifications to the scope scheduled work; p lens in delivery, procurement, etc.; cha es in NRC rules and regula fons; or other NRC or SCE actions.
Where it is ne ssary to add a new work ites or to change the schedule for an em, the following general g dance will be utilized to the ex nt appropriate:
Determine the prio ity of the project or changed priority, using the Westingho e Analytical Ra king Process.
Schedule the.new or cha ed item t avoid rescheduling other items already well underw y if 1 can be reasonably achieved.
Alter Schedule B and C items 'b ore Schedule A items.
Select a schedule for the ne or' changed ites which will help maintain an optimum integra
- d. program of work.
If a new Schedule A item is ad d, regardless of the results of the above ranking / scheduling pro s, the implementation schedule of the new ites shall comply with a licable NRC regulations, orders, or license conditions unless a ifferent schedule has been formally established in accordance th appropriate Coamission procedures.
As noted above, no chang s will be made to Schedule A without prior NRC approval. Should a change become necessary, it will only be proposed after SCE has determined that rescheduling of lower priority work either ill not significantly assist in maintaining Schedule A without c ange, or that the safety, cost or schedule penalties froe rese eduling lower priority work significantly outwigh the chan in a Schedule A cospletion date.
SCE will inform he NRC Project Manager when serious consideration is given to esting a change in Schedule A.
When SCE determines that a change n Schedule A is necessary, it will submit a written request for N C approval in accordance with applicable procedures.
SCE will no ify ?!RC in writing at least 30 days before adopting a planned de ay for an item in Schedule B.
Such notification will also include tye reasons for 'the delay and describe any compensatory actions indicated. The revised date proposed by SCE will go into effect
(
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r 1 unless NRC, in writing, requests further explanation or discussion concerning such change.
If NRC makes such a request, it will be made within 15 days of receipt of SCE'S written notification.
In this event, discussions will be initiated to promptly develop a schedule date which is mutually acceptable to SCE and the NRC Project Manager while considering overall program impact. The itten notification by NRC will serve to extend the schedule ate f
the period of time required for such discussions. If a ew date i
is e tablished in these discussions such date will supers e the date t forth in Schedule 8.
The new date will be inco porated in a revis Schedule B in the next semi-annual schedule date submitted o NRC.
If a new data cannot be establish in these discussions, SCE changes in scheduled dates will be effective unless subsequently dified by NRC Order.
Work items in Sch dule C may be ruscheduled or ork'itens may be added to Schedule by SCE without NRC notif atton. SCE will report changes to Sc edule C items in its s 1-annual update to be provided in accordanc with Section V.A a ve. This schedule is e
provided fur informatio purposes only a is intended to provide 4
the NRC a better understa ding of the it's overall modifications program.
VI. NRC REVIEW As pointed out in.Section V.B above, anges to the schedules are inevitable, Actions required by th NR are oiscussed below:
A.
Southern California Edison iginated hanges 1.
Upon receipt from SC of a request modification of Schedule A, NRC will act p ptly (consistent w h resource availability anc priority of o er work) to act on th request in accordance with applicable rocedures.
2.
If the reques for a modification 'of Schedule is denied, the NRC shall pr tly inform SCE and provide the r asons for denial.
3.
NRC cons deration of SCE changes in non-Schedule A ems is covere by V.S above.
B.
MRC Origi ated Chances -(Schedule A)
It is ecognized that formal NRC regulatory actions ma (1)i pse regulatory requirement with a fixed date or (2) y:
an establish a fi date for a previously identi: ed regulatory requirement.
In t ing any such action, the NRC, to the extent consistent with this verall regulatory responsibilities and, unless public health, JULl7 E NENmE2n 10. 60
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safety, or interest require otherwise, will take into account the impact of such action on SCE's ability to complete effectively the items on Schedules A, B and C and, in consultation with SCE, 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 SCE recognize he irability of incorporating such action into Schedule par larly in order to incorporate at the same time y other approp te changes in the total integrated schedul rogram.
According
, once such formal regulatory action is aken(or earlier, if racticable), the NRC will provide 5 a reasonable opportunity t repose overall changes in the tal integrated schedule progra which would most effectively acconnodate such require-ments. Any resul ng changes in items in 5 edule A will be submitted to the NRC for revi in accordance with tablished procedures, and, if approved by the Co ission, will ther pon be reflected in a revised Schedule A submitted by CE. SCE will nform the NRC of any resulting changes in Schedule B in cordance w h Section V above.
C.
New HRC !ssues (Schedule B)
J The NRC may, from time to time ide ify new regulatory issues whic'h may result in (a) plant modif ations, (b) procedure revision or development, or (c) changes n facility taffing requirements.
For issues'on.which the NRC requests sche ling information, these issues may be included in chedule B in acco ance with the date connitment devaluped in scussion between SC nd the NRC staff.
As for the case of HRC riginated changes to Sch ule A items, the NRC will provide SCE a reasonable opportunity to p pose overall changes in the total ntegrated schedule program wh h would most effectively acconno te such issues. Any resulting c nges in integrated program chedules will thereupon be reflect in a revised Schedule submitted by SCE.
VII. MODIFICATIONS TO TH PLAN The licensees and the NRC recognize that the Plan itself may require future modificat ons. Accordingly, SCE will draft proposed modifications and submit a 1 anse amendment applicat1on for approval of the proposed changes. The hanges, if approved, will be made effective spon aswndment issuance by e NRC.
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