ML20132C292
| ML20132C292 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 07/17/1985 |
| From: | Musolf D NORTHERN STATES POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GL-85-07, GL-85-7, NUDOCS 8507300118 | |
| Download: ML20132C292 (4) | |
Text
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Northem States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401 Telephone (612) 330-5500 July 17, 1985 Director Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 Prairie Island Nuclear Generating Plant Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Response to NRC Generic Letter 85-07 Implementation of Integrated Living Schedule The purpose of this letter is to provide, for the information of the NRC Staff, our response to Generic Letter 85-07 dated May 2, 1985.
This letter requested our views on the Integrated Living Schedule (ILS) concept as adopted at the Duane Arnold Energy Center.
Northern States States Power Company has reviewed the concept of an ILS implemented through an amendment to the plant opera-ting license.
We do not, at this time, believe that an ILS of this type is needed.
This decision is based on the following considerations:
Manageable Backlog of NRC Required Modifications The number of outstanding actions required as a result of the NRC TMI Action Plan and the large number of Bulletins and Orders issued beginning in 1979 is now of manageable size.
Improvement in NRC Approach in Issuing New Requirements The NRC has in recent years displayed a sensitivity to the problems associated with the imposition of arbitrary deadlines for satisfying new requirements.
The procedure followed by the NRC Staff in establishing completion schedules for NUREG-0737 Supplement No. 1 modifications is an example of this.
Schedules for required modifica-tions were discussed with the NRC Project Manager in the v
Division of Licensing for our plant.
Availability of utility resources and outage schedules were considera-tions in arriving at a final implementation schedule which was later documented in an NRC Confirmatory Order.
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Northom States Power Company i
Director of NRR July 17, 1985 Page 2 Efforts of the NRC Committee to Review Generic Requirements (CRGR) and backfit rulemaking activities provide additional assurance that reasonable schedules will be established in the future for NRC required l
actions.
i Willingness of NRC Staff to Approve Schedule changes If a Showing of " Good cause" is Made by Utility l'
The NRC Staff has recently shown reasonable flexibility in granting schedule relief for completing NRC required backfit modifications if " good cause" is shown.
For j
example, Confirmatory Orders for NUREG-0737 Supplement No. I requirements contained this provision.
Northern States Power Company recognizes, however, the need to integrate new NRC requirements with other requirements such as refueling outage schedules, maintenance plans, and scheduled i
plant upgrades and refurbishment.
We have, as a goal, the development of a long range plan for each of our nuclear generating plants.
This plan, as currently conceived, would include commitments to NRC requirements as well as all other major activities taking place over a five-year interval.
This plan would primarily be a management tool for use by Northern States Power Company to more effectively allocate human and financial resources.
It would be our intention to use this plan in discussions with the NRC Staff to support schedules we would propose for completing NRC required actions.
Please contact us if you have any questions related to the information we have provided.
Attached is the completed ques-tionnaire which was provided to us as Enclosure (2) to Generic Letter 85-07.
As discussed above, the option we have chosen is the implementation of an informal ILS.
D& W-David Musolf Manager - Nuclear Su port Services c: Regional Administrator III, NRC Resident Inspector, NRC NRR Project Manager, NRC G Charnoff i
Attachment s
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?t ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-PLANT NAME:
Prairie Island Nucient Generating P1nne UTILITY:
Northern States Power Company I.
INTENTIONS A.
Intend to work with the staff to develop an ILS B.
Have reservations that must be resolved before developing ILS C.
Do not presently intend to negotiate an ILS with the staff D.
Plan to implement an informal ILS only x
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:
Engineering judgement Analytic Hitarchy process Risk based analysis Cost-benefit analysis Other (please describe)
If no, provide estimated date for selecting a methodology:
Date or If not presently available, provide estimated date for scheduling the selection of a methodology:
2.
What is your estimated date for making a submittal to the NRC-or If not presently available, planned date for scheduling a submittal to the NRC
(
3.
If you answered I.S above:
1.
olease exclain your reservations en secarate sheet (s) or orevide your schedule for suaalving an explanatien
'See separate sheet (s) of Seoarate submittal scheduled for (0 ate) 2.
If available to meet with the staff to discuss your concerns, propose a time frame for such a meetinc and orovide a contact that can make arrangements Contac,t/ Time Frame Phone Number C.
If you answered I.C 1.
Would you he willing to meet with the staff to discuss the deveicoment of an ILS for your factif ty(s)?
Circle One:
Yes No If yes, procese a tire frame #ne such a meeting and provide a contact that can rake arrangements.
Contact Time Frame Chene Number
!f no, any c.tnstructive c:mments you have would be accreciated.
III.
A00!TIONAL *TEMS Dlease make any sucgestions you.-ay have as to how a utiitty sconsored availability /reliacility project might be credited 'or p! ant safety enhancemer?, Provide aeditional constructive comments as accroorf ate.
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