ML20128M805
| ML20128M805 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/25/1985 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20128M808 | List: |
| References | |
| 1160, GL-85-07, GL-85-7, NUDOCS 8507120641 | |
| Download: ML20128M805 (7) | |
Text
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Docket No. 50-346 TOLEDO License No. NPF-3 l!E)lEI()d Serial No. 1160 RICHARD P CccuEE w, m.w-June 25, 1985
.m. F wn;&n u Director of Nuclear Reactor Regulation Attention:
Mr. John F. Stolz Operating Reactor Branch No. 4 Division of Licensing United States Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Stolz:
This letter is in response to Generic Letter 85-07, " Implementation of Integrated Schedules for Plant Modifications", dated May 2, 1985 (Log No. 1738), from Mr. Hugh L. Thompson, Jr.
As you are aware, The Toledo Edison Company (TED) has been working on the development of an internal management program since late 1982.
This program was designed to improve the management of our resources and com-mitments, thus, and in part, provide a realistic and achievable schedule that could be endorsed by Toledo Edison and the Nuclear Regulatory Com-mission (NRC).
Our intentions for the development of this' program were outlined in a presentation to the NRC on February 16, 1983, and since that time, in Serial No. 996, dated January 20, 1984; No. 1043, dated July 16, 1984; No. 1061, dated August 4, 1984; No. 1092, dated October 30, 1984; and No. 1154, dated July 1, 1985.
Attachment I to this letter outlines the milestones in the development of the program over the past two years, which. Toledo Edison has labeled the Integrated Living Schedule Program (ILSP). to this letter provides part of our response to Enclosure 2 of Generic Letter 85-07.
The balance of our response is contained below in the section titled " Concerns for Discussion and Resolution".
Currently, it is our intention to submit our revised ILSP License Amend-ment request on August 1, 1985.
In the interim, we would like to meet with your staff to clarifp certain questions arising from our interpre-tation of Generic Letter 85-07.
We are working with Mr. Albert W. DeAgazio, the Nuclear Reactor Regulation (NRR) Project Manager for Davis-Besse on scheduling this meeting.
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PDR THE TOLEOO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43G52 l
Dsck2t Ns. 50-346 License No. NPF-3 Serial No. 1160 June 25, 1985 Page 2 As part of the agenda for,this meeting, Toledo Edison would like to dis-cuss the policy statements in Generic Letter 85-07 for clarification in-cluding; (1) the methods with which the NRC will internally manage the overall program; and (2) the NRC's methods for management of the unique ILS programs.
The following paragraphs briefly identify our area of concern. We pro-pose that the details of this concern be addressed at the proposed meeting with your staff. Attendees should be familiar with our submittal, Serial No. 1154, which has been included as Attachment 3 to this letter.
Concern for Discussion and Resolution Toledo Edison agrees with the opening paragraph in Enclosure 1 of Generic Letter 85-07, which states, "...It is not intended nor would it be appro-priate, for the NRC to become involved in the licensee's financial planning and funding processes for... plant improvements...".
Toledo Edison further interprets this statement to include other management processes such 'au estimating and prioritization. The adequacy of'the pro-cess is the utility's responsibility. The acceptability of the.end product (ILSP schedule and supporting documentation) falls under the NRC's purview, assuming an approved ILS license amendment has been issued.
Over the past two years, the majority of the discussions on the Toledo Edison ILSP have taken place with Mr. DeAgazio.
Mr. DeAgazio's input /com-ments to our ILSP Plan have helped to develop an acceptable approach to managing plant improvements. We feel strongly that the proper forum for discussing ILSP schedules and evaluation of the ILSP documentation also lies with the NRR Project Managers and the Office of Nuclear Reactor Regulation, rather than the Office of Inspection & Enforcement (OI&E) or Regional Offices.
Our major concern is with the "... regional review of program implementa-tion...", and the potential development of an inspection module for Inte-grated Living Schedule (ILS) programs. Toledo Edison feels that the com-pliance assessment for the proposed license amendment should be limited to the existence of a schedule of plant improvements, acceptable to both Toledo Edison and the NRR. Since the Toledo Edison ILSP Plan specifically allows NRR comment and input for schedule adjustments, the Toledo Edison ILSP schedule will have NRC acceptance. Therefore, auditing of a process that produces a mutually acceptable schedule is not required.
Dack;t No. 50-346 License No. NPF-3 Serial No. 1160 June 25, 1985 Page 3 Additionally, this ILS concept is voluntary and should be viewed as a management tool to support mutually desired objectives. A regional audit goes beyond what we feel is intended or necessary under a voluntary program.
We certainly agree that the Region and the Site Resident Inspector should be aware of the program, its intent, and be kept appraised of the ILSP schedule and status. However, the acceptability of program implementation should be confined to the acceptability of the schedule and the availabil-ity/ maintenance of the suppcrting documentation for schedular change, ad-ditions, or deletions.
The ILSP is a management process and involves subjective decision making based largely on constantly changing information and management judgement.
These judgemental processes do not lend themselves to proceduralization.
Therefore, to submit processes such as estimating, budgeting, planning, scheduling, and prioritization into a regional compliance assessment activ-ity is not desirable. Toledo Edison feels strongly that the NRR should maintain the lead for assessing the adequacy of the ILSP submittals and compliance to the license amendments.
In closing, Toledo Edison would like to reiterate our strong support for the ILS concept as proposed in our Serial No. 1154 and your Generic Letter 85-07.
The philosophies and intent of these documents appear consistent and have great potential for improving mutual understanding of resource constraints and priorities. We look forward to meeting with your staff to further discuss these matters.
Very truly yours,
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RPC:DBI:nif encl.
cc: DB-1 NRC Resident Inspector
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TOLEDO EDISON INTEGRATED LIVING SCHEDULE PROGRAM (ILSP)
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AUGUST, 1982 OUTAGE COSTS / BUDGET OVERRUN g y f, SEPTEMBER, 1982 BUDGET ADHERENCE COMMITTEE SEPTEMBER, 1982 CAPITAL WORK SCOPE COMMITTEE OCTOBER, 1982 TECHNICAL EVALUATION GROUP (TEG) - ASSESSMENT PROCESS DECEMBER, 1982 BOARD OF DIRECTORS APPROVAL OF 1983 IMPLEMENTATION SCHEDULE (IMP SCH)
JANUARY, 1983
_ PLANNING EVALUATION GROUP (PVC)
FEBRUARY, 1983 PRESENTATION OF TOLEDO EDISON INTEGRATED LIVING SCHEDULE CONCEPT TO NRC JUNE, 1983 ADJUSTMENTS TO 1983 IMP SCH BASED ON TEG/PVC INPUT DECEMBER, 1983 BOARD OF DIRECTORS APPROVAL OF 1984 IMP SCH JANUARY, 1984 DRAFT ILSP PLAN SUBMITTED FOR NUCLEAR REACTOR REGULATION COMMENT (SERIAL NO. 996)
MARCH, APRIL, 1984 MEETINGS WITH NRC TO DISCUSS COMMENTS WITH SERIAL NO. 996 JULY, 1984 TOLEDO EDISON SUBMITTED ILSP PLAN, INCLUDING NRC INPUT (SERIAL NO. 1043)
AUGUST, 1984 TOLEDO EDISON SUBMITTED ILSP LICENSE AMENDMENT REQUEST (SERIAL NO. 1061)
OCTOBER, 1984 TOLEDO EDISON /NRC STAFF MEETING TO DISCUSS PLAN OCTOBER, 1984 TOLEDO EDISON SUBMITTED ILSP SCHEDULE (SERIAL NO. 1092)
DECEMBER, 1984 BOARD OF DIRECTORS APPROVAL OF 1985 IMP SCH FEBRUARY, APRIL, NRC LEGAL COMMENTS RECEIVED AND INCORPORATED INTO REVISED PLAN 1985 JUNE, 1985 TOLEDO EDISON SUBMITTED REVISED ILSP PLAN (SERIAL NO. 1154)
Dockat No. 50-346 Lican:s No. NPF-3 Serial No. 1160 Page 1 of 2 ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-PLANT NAME:
Davis-Besse Unit 1 UTILITY:
The Toledo Edison Company I.
INTENTIONS A.
Intend to work with the staff to develop an X
(In progress)
}L3 B.
Have reservations that must be resolved X
.(Responsibility before develepteg ILS t submitting f r Compliance C.
Do not presently intend to negotiate an Assessment)
ILS with the staff D.
Plan to implement an informal ILS only II.
STATUS A.
If you answered I.A above:
1.
Have you settled on a method for prioritizing the work at your plant (s)?
Circle One:
Yes No If yes, select best description:
- 1. Engineering judgement Analytic Hiearchy process
- 2. Risk based analysis
- 3. Cost-benefit analysis Other (please describe) combination of 1, 2 6 3 Three levels, depending on Information available (project maturity in If no, provide estimated date Engineering) for selecting a methtdology:
Date or If not presently available, provide estimated date for schedul-ing the selection of a methodology:
?.
What is your estimated date for making a submittal to the NRC-8/1/85 (Request for License Ameni or ment)
If not presently available, planned date for scheduling a submittal to the NRC
l Dock t No. 50-346 l
Lic:nsa No. NPF-3 Ssrial No. 1160 l
Page 2 of 2 i
B.
If you answered I.B above:
l.
Please explain your reservations on separate sheet (s) or provide your schedule for supplying an explanation See separate sheet (s) x of Separate submittal scheduled for (Date) 2.
If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame R..F.
Peters (Early July)
Phone Number (419)249-5375 C.
If you answered I.C 1.
Would you be willing to meet with the staff to discuss the development of an ILS for your facility (s)?
Circle One:
Yes No If yes, propose a time frame for such a meeting and provide a contact that can make arrangements.
Contact Time Frame Phone Number If no, any constructive comments you have would be appreciated.
III.
ADDITIONAL ITEMS Please make any supgestions you may have as to how a utility sponsored availability / reliability pro,iect night be credited for plant safety enhancement.
Provide additional constructive comments as appropriate.
Docket No. 50-346 Lic:nea No. NPF-3 Serisl No. 1160 July 1, 1985 ATTACILMENT 3 SERIAL NO. 1154 (19 pages)
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