ML20134P942

Forwards Changes to 850607 Application for Amend to License DPR-6,requiring Adherence to Plant Integrated Assessment Plan.Changes Reflect Methods of Planning & Scheduling Resource Expenditures on Integrated Assessment Issues

ML20134P942
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/03/1985
From:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8509090105
Download: ML20134P942 (11)

Text

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Nuclear licensmg General offees- 1945 West Parnall Road, Jackson, MI 49201 e (517) 788-1636 September 3, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

MINOR CHANGES TO THE PROPOSED OPERATING LICENSE CHANGE REQUEST FOR THE INTEGRATED ASSESSMENT Consumers Power Company letter dated June 7, 1985 submitted a proposed change to the Big Rock Point Plant Operating License which will require adherence to the " Plan for the Big Rock Point Integrated Assessment." The "Plin" was included in this letter as an attachment. Minor changes to the " Plan" are needed to accurately reflect the methods by which the resources expended on Integrated Assessment issues are planned and scheduled. These changes are described below.

Section III of the " Plan" describes the methods by which Integrated Assessment issues are assessed and scheduled, and specifies that critical path methodology is employed in scheduling tasks associated with issue resolution and that completion schedules identify critical paths in the work effort.

Experience gained during the past two years has shown that most of the work effort to complete Integrated Assessment issues is of such scope and duration that application of critical path methodology is unwarranted. Critical path scheduling methods may be used, however, on a case by case basis, depending on the scope, duration and complexity of activities associated with the resolution of one or more issues. Furthermore, progress on the completion of all Integrated Assessment issues will be periodically monitored to determine if corrective actions, such as the application of critical path scheduling methods, are needed to ensure that for the most part resources are utilized efficiently and completion schedules are met.  ;

Based on the explanation given above, Consumers Power Company requests that the following changes be made to the " Plan for the Big Rock Point Integrated Assesament," submitted to the NRC by letter dated June 7, 1985.

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' Big Rock Point Pl:.nt Proposed Operating Lidense Change Raouest September 3, 1985

1.Section III, first paragraph, fourth sentence: Change to read "Upon TRG completion of the issue assessment and ranking (using, in some cases, the results of probabilistic risk assessment studies), the tasks associated with each issue resolution were scheduled based on their assigned ranking and available resources."

2.Section III, first paragraph, sixth sentence: Change to read

" Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recover plans."

A revised " Plan for the Big Rock Point Integrated Assessment," with the above changes to section III identified by bars in the right-hand margin, is provided in Attachment I.

Please note that the June 7, 1985 letter submitting the Operating License change request and the " Plan" supersedes all previous submittals describing the methods by which the Integrated Assessment is implemented at the Big Rock Point Plant.

. (_).)./7 h David J VandeWalle Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point i

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• CORSumerS power o.via a v.no.w.ii.

Durcwr of Nuclear Luenung General offices 1945 West Parnali Road, Jackson. MI 49201 (517) 768 1636 September 3, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

MINOR CHANGES TO THE PROPOSED OPERATING LICENSE C1ANGE REQUEST FOR THE INTEGRATED ASSESSMENT Consumers Power Company letter dated June 7, 1985 submitted a proposed change to the Big Rock Point Plant Operating License which will require adherence to the " Plan for the Big Rock Point Integrated Assessment." The " Plan" was included in this letter as an attachment. Minor changes to the " Plan" are needed to accurately reflect the methods by which the resources expended on Integrated Assessment issues are planned and scheduled. These changes are described below.

Section III of the " Plan" describes the methods by which Integrated Assessment issues are assessed and scheduled, and specifies that critical path methodology is employed in scheduling tasks associated with issue resolution and that completion schedules identify critical paths in the work effort.

Experience gained during the past two years has shown that most of the work effort to complete Integrated Assessment issues is of such scope and duration that application of critical path methodology is unwarranted. Critical path scheduling methods may be used, however, on a case by case basis, depending on the scope, duration and complexity of activities associated with the resolution of one or more issues. Furthermore, progress on the completion of all Integrated Assessment issues will be periodically monitored to determine if corrective actions, such as the application of critical path scheduling methods, are needed to ensure that for the most part resources are utilized efficiently and completion schedules are met.

Based on the explanation given above, Consumers Power Company requests that the following changes be made to the " Plan for the Big Rock Point Integrated Assessment," submitted to the NRC by letter dated June 7, 1985.

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Dircctor, Nuclear Reactor Regulation 2 Big Rock Point Plant Proposed Operating License Change Request September 3, 1985

1.Section III, first paragraph, fourth sentence: Change to read "Upon TRG completion of the issue assessment and ranking (using, in some cases, the results of probabilistic risk assessment studies), the tasks associated with each issue resolution were scheduled based on their assigned ranking and available resources."

2.Section III, first paragraph, sixth sentence: Change to read

" Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recover plans."

A revised " Plan for the Big Rock Point Integrated Assessment," with the above changes to section III identified by bars in the right-hand margin, is provided in Attachment I.

Please note that the June 7, 1985 letter submitting the Operating License change request and the " Plan" supersedes all previous submittals describing the methods by which the Integrated Assessment is implemented at the Big Rock Point Plant.

David J VandeWalle (Signed)

David J VandeWalle Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point OC0885-0262-NLO4

ATTACHMENT I Consumers Power Company Big Rock Point Plant Docket 50-155 REVISIED PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT September 3, 1985 6 Pages IC0885-0262-NLO4

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PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT I. INTRODUCTION

Consumers Power Company (CPC) has developed a comprehensive program which will enable the Company to effectively manage implementation of significant changes to our Big Rock Point Plant which have been required, or proposed by, the NRC, as well as other measures to enhance plant safety and reliability which have been identified by the Company or other agencies (eg, the Institute of Nuclear Power Operations). A description of the program, identified as the " Integrated Assessment of Open Issues and Schedule for Issue Resolution (Including Environmental Equipment Qualification and Generic Letter 82-33 Issues)" was submitted to the NRC by our letter dated June 1, 1983.

This program was developed to assess, coordinate and schedule all necessary work at the Big Rock Point Plant, including those mandated or proposed by the NRC, or identified by CPC and others. The program objectives are to (1) satisfy regulatory requirements; (2) provide sufficient lead times for modifications; (3) minimize changes to operators; (4) effectively manage financial and human resources; and (5) specify the framework for changes to developed issue resolutions and associated schedules. This will be accomplished within the overall objective of plant safety and availability.

This program reflects the recognition by CPC and the NRC that fiscal and manpower resources are finite and that a limit on the onsite manpower is necessary. The program integrates a significant portion of presently planned work at the Big Rock Point Plant over a nominal three-year pariod to ensure that individual issues are properly assessed and that the tasks associated with issue resolution are effectively scheduled and coordinated. It provides a means for new requirements to be accommo-dated takir.g into account schedule and resource constraints, as well as the importance of implementing a new requirement. The purpose of this document is to describe the plan used to implement the program. It describes how the program functions, mechanisms for changing the program and updating it, the interactions and responsibilities of the NRC and licensee staffs under the program, and its resultant assessments and schedules.

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SUMMARY

OF PROGPAM DEVELOPMENT The program is based on a list of issues, their associated resolutions and completion dates, each of which is assigned a priority resulting from an established assessment method. Assessments are performed by the Big Rock Point Plant Technical Review Group (TRG), and the assessment

, method involves ranking each issue or issue resolution based on its importance relative to safe shutdown, radiological release potential, personnel safety, and plant availability. The scheduling of issue resolutions takes into account projections for budgets and site manpower and engineering support requirements for three years, on an item-by-item TSB0585-0017D-NLO2

2 of 6 i i basis covering all significant plant modification activities. The list represents that significant portion of the Big Rock Point Plant work list and commitment list which is regularly modified and updated to meet changing conditions, including new NRC regulatory requirements. The final product of this program is the assessment of issues or issue resolutions and the development of associated schedules as discussed below.

III. ASSESSMENT AND SCHEDULING A first step in the development of this program involved a listing of significant open issues and their associated resolutions. In cases where a resolution to a particular open issue was not yet identified, the issue itself was retained in the list. Upon completion of the work listing, CPC determined that an assessment of issues or issue resolu-

tions was required to determine their appropriate ranking. Upon TRG i completion of the issue assessment and ranking (using, in some cases, the results of probabilistic risk assessment studies), the tasks associated with each issue resolution were scheduled based on their assigned ranking and available resources. The issues or issue resolutions were organized into Issue Groups A and B based upon the origin of the issue and its ranking. Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recovery plans. Both Issue Groups are briefly described below

Issue Group A - All issues which have resolutions and/or issue resolution implementation dates mandated by NRC rules, orders or license conditions.

J Issue Group B - Issues (of either a generic or plant specific nature) identified by the NRC or CPC which have resolutions and/or completion dates requested by the NRC and/or committed to by CPC, and which would result in either a) plant modifications, b) procedure revisions, or c) changes in facility staffing requirements.

Issue resolutions and/or implementation dates in Issue Group A may be modified or deleted only with prior approval of the NRC, in accordance with existing NRC procedures. Changes to the issue resolution and/or completion dates in Issue Group B require notification to the NRC as described in Section V. Issue Groups A and B, taken together, provide a basis for assessing the overall effects of changes to issue resolutions and/or schedules, and a departure point for discussion between the NRC and the licensee regarding such changes, as discussed below.

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. 3 of 6 It should be noted that activities categorized in Issue Group A should not be considered to have any more or less safety significance than Issue Group B activities. Issue Group A activities simply have a resolution and/or schedule that is " fixed" without prior NRC approval of changes.

IV. ISSUE RESOLUTION AND SCHEDULE MODIFICATIONS An important aspect of CPC's planning effort is the recognition that the issues, issue resolutions, and scheduled completion dates will need to be modified or deleted at times to reflect changes in regulatory requirements, to accommodate those activities that CPC finds necessary to improve plant efficiency and reliability, to incorporate the results of investigations into issues, and to take into account delays resulting from events beyond CFC's control. The procedure used by CPC for chang-ing or deleting issues, issue resolutions, or scheduled completion dates i will be developed and included in a separate volume of the Big Rock Point Plant Manuals. y V. CPC AND NRC RESPONSIBILITIES The proper functioning of the Integrated Plan requires that CPC apply consistent criteria to the assessment of issues, monitor the progress of all work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when an issue resolution or schedule change is needed. It also requires that the NRC treat all Integrated Plan issues consistently and recognize that, when necessary, ranking _ issue resolutions, and/or scheduled completion date changes are l based on a comparison of the issue being changed to all the Integrated Plan issues, and also account for resource constraints.

! A. PERIODIC UPDATING CPC will update Issue Groups A and B semi-annually and submit the revised Integrated Plan to the NRC, beginning six months following NRC approval of this plan. The revised Integrated Plan will include the following:

• Summarize progress in completing or implementing issue resolutions.

• Identify changes since last update report.

• Summarize the reasons for issue resolution and/or schedule changes

associated with regulatory requirements.

, 1 The listing of issues in Issue Groups A and B will contain sufficient detail to identify those issues with tasks and/or completion dates keyed to refueling outages. In such cases, a change in outage period (ie, initiation or duration) shall not be considered a schedule change.

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. 4 of 6 B. CHANGES TO ISSUE RESOLUTIONS AND/OR SCHEDULES Changes to the Integrated Plan may arise from a variety of reasons, such as new issues identified; modifications to the scope of scheduled work; unplanned outages; results of investigations into an issue (eg, PRA findings); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or CPC actions.

Where it is necessary to add a new issue or to change the schedule for an issue, the following general guidance will be utilized to the extent appropriate:

• Assess the priority of the issue relative to all existing Integrated Plan issue resolutions.

• Schedule the new or changed issue resolution to avoid rescheduling other issues, if it can be reasonably :chieved.

• Alter Issue Group B items before Issue Group A items.

• Select a schedule for the new or changed issue resolution which will help in maintaining an optimum integrated program of work.

Addition of activities to Issue Group A requires CPC to propose appropriate issue resolutions and/or completion dates and requires NRC approval of such proposals. Changes to previously established Issue Group A resolutions and/or resolution implementation dates will be proposed only af ter CPC has determined that changing Issue Group B issues will not significantly assist in maintaining Issue Group A without change; or that safety, resource or schedule penalties from rescheduling Issue Group B activities significantly outweigh the consequences of a change in an Issue Group A completica date. As with proposals to add Issue Group A activities, proposals to change previously existing Issue Group A activities also requires NRC approval.

CPC will inform the NRC Project Manager when serious consideration is given to requesting a change in Issue Group A. When CPC deter-mines that a change in Issue Group A is necessary, it will submit a written request for NRC approval in accordance with applicable procedures.

Issue resolutions in Issue Group B may be modified, deleted or rescheduled, or new issues may be added to Issue B by CPC without NRC approval; however, CPC will inform the NRC Project Manager once it has been determined that a change, deletion, or addition is necessary. CPC will provide the NRC with timely written notifica-tion of changes or deletions of Issue Group B issue resolutions or completion dates associated with NRC initiated issues. Such notifi-cation will also include the reasons for the change and describe any compensatory actions which CPC determines to be appropriate.

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The change, addition or deletion in Issue Group B will go into effect upon evaluation by the TRG, unless the NRC, in writing, requests further explanation or discussion. Such a request shall be made in a timely manner. In this event, discussions will be initi-ated to promptly develop an issue resolution and/or schedule which is mutually acceptable-to CPC and the NRC Project Manager while considering overall program impact. The written notification by the NRC will serve to extend the schedule date for the period of time required for such discussion. If a revised issue resolution and/or i

schedule is established in these discussions, such issue resolution and/or schedule will supersede the issue resolution and/or schedule '

set.forth in Issue Group B. The revised issue resolution and/or schedule will be incorporated in a revised Issue Group B in the next l

update submitted to the NRC. If a revised issue resolution and/or schedule cannot be established in these discussions, CPC changes to

issue resolutions and/or schedule dates will be effective unless subsequently modified by NRC Order.

In the event of unplanned delays or circumstances beyond CPC's control, CPC shall provide timely notification to the NRC Project Manager of the revised issue resolution and/or schecule date and incorporate it in a revised Issue Group B in the next update submitted to the NRC.

VI. NRC REVIEW As pointed out in Section V.B above, changes to the issues and/or schedules are inevitable. Action required by the NRC is discussed below:

1 A. CONSUMERS POWER COMPANY ORIGINATED CHANGES

1. Upon receipt from CPC of a request for modification of Issue Group A, the NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the request in accordance with applicable procedures.

2. If the request for a modification of Issue Group A is denied, NRC shall promptly inform CPC and provide the reasons for denial.

3. NRC consideration of CPC changes to non-Issue Group A issues and/or schedules is covered by Section V.B.

B. NRC ORIGINATED CHANGES (ISSUE GROUP A)

It is recognized that formal NRC regulatory actions (ie, NRC rules, orders, or license conditions) may: (1) impose a new regulatory requirement with a fixed date, or (2) establish a firm date for a previously identified regulatory requirement.- In taking any such l action, the NRC, to the extent consistent with its overall regulatory responsibilities and, unless public health, safety, or TSB0585-0017D-NLO2

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interest require otherwise, will take into account the impact of such action on CPC's ability to complete effectively the issues in Issue Groups A and B, and, in consultation with CPC, will try to minimize such impact. Although any formal regulatory action (ie, regulatory rule, order, or license condition) taken by the NRC will be effective in accordance with its terms without inclusion in Issue Group A, the NRC and CPC recognize the desirability of incorporating such action into Issue Group A, particularly in order to incorporate at the same time any other appropriate changes in the total inte-grated assessment program. Accordingly, once such formal regulatory

action is taken (or earlier, if practicable), the NRC will provide CPC a reasonable opportunity to propose overall changes in the total integrated assessment program which would most effectively accom-modate such requirements. Any resulting changes in issues in Issue l Group A will be (1) reviewed by the NRC, taking in account the oveall objective of the Integrated Assessment Program to use available resources effectively, and (2) approved by the NRC in accordance with established procedures, and will thereupon be reflected in a revised Issue Group A submitted by CPC. CPC will inform the NRC of any resulting changes in Issue Group B in accord-ance with Section V above.

C. NEW NRC ISSUES (ISSUE GROUP B)

The NRC may, from time to time, identify new regulatory issues which may result in (a) plant modifications, (b) procedure revision or development, or (c) changes in facility staffing requirements. With respect to issues which the NRC requests (1) scheduling information or (2) responses by a certain date, these issues may be included in issue Group B in accordance with the issue resolution priority

resulting from the TRG assessment. Issue resolutions and/or date commitments resulting from TRG evaluation will form the basis for discussions between the NRC and CPC. As for the case of NRC-originated changes to Issue Group A issues, the NRC will provide CPC a reasonable opportunity to propose overall changes in the total integrated plan program which would most effectively accommodate such issues. Any resulting changes in the integrated plan program will thereupon be reflected in a revised Issue Group B submitted by CPC.

VII. MODIFICATION TO THE PLAN The licensee and the NRC recognize that the Plan itself may require future modifications. Accordingly, for revisions which are determined to be substantial, CPC will submit these changes for approval. The changes will be made effective upon amendment issuance by the NRC.

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