ML20137U366

Forwards Revised Plan for Big Rock Point Integrated Assessment,Addressing NRC Concerns Raised During Preliminary Review of 850607 Request for Proposed Change to License DPR-6

ML20137U366
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/04/1985
From:	Frisch R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8512090281
Download: ML20137U366 (8)

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. Consumers Power Company General Officest 1945 West Parnell Road, Jackson, MI 49201 * (5171 788-0660 December 4, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555

-DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

PROPOSED OPERATINC LICENSE Cl!ANGE REQUEST -

INTEGRATED ASSESSMENT, SUPPLEMENTAL INFORMATION Consumers Power Company letter dated June 7, 1985, as modified by our

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September 3, 1985 letter submitted a proposed license change request to incorporate the " Plan for the Big Rock Point Integrated Assessment" into Big Rock Point's operating license. This submittal provides supplemental information to address NRC concerns raised during preliminary staff review.

Attached is a revised " Plan for the Big Rock Point Integrated Assessment" which contains changes made to resolve preliminary staff concerns. These changes have been previously discussed and agreed upon between respective members of our staffs and are intended to minimize vagueness and to provide clarification within the Plan.

Pursuant to 10CFR170.12(c) a check in the amount of $150.00 was attached to our June 7, 1985 submittal, hence no fee is remitted with this submittal.

iAA.40 L Ra1 h R Frisch Senior Licensing Analyst CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Plant Attachment 05120902B1 B512Oj55 ppg ADOCK 050 g P 4 s \

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}P' ATTACHMENT Consumers Power Company Big Rock Point' Plant

-- ( - Docket 50-155

^i REVISED PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT December 4, 1985 i

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[ 1 of 6 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 1 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 s 'to the NRC by our letter dated June 1, 1983. The tern Issue Resolution as used herein refers to the actions necessary to resolve concerne

-(safety related or otherwise) which have been identified by the NRC or CPC. This may include analyses, studies and/or plant modifications.

'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) sinimise changes for

,. 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 L 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 period to ensure that individual' issues are properly assessed and that the taska-associated with issue resolution are effectively scheduled and

! coordinated. It provides a means for new requirements to be accommo-dated 'taking into account schedule and resource constraints, as well as the importance of implementing a new requirement. The purpose of this g document is to describe the plan used to implement the program. It L 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.

II. .st2 DIARY OF PROGRAM DEVELOPMENT

[ The program is based on a list of issues, their associated resolutions l- 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 Croup (TRG), and the Assessment

,sethod' involves ranking each issue or issue resolution based ca its importance relative to safe shutdown, radiological release potential,

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F personnel. safety, and-plant svailability. The scheduling of issue h resolutions takes into accour.t projections for budgets and site manpower h

and engineering support requirements for three years, on an item-by-item basis' covering a11'significant plant modification activities. The list represents that significant portion of the Big Rock Point Plant work

l. list and conniement list which is regularly modified and updated to meet k

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. ASSESSMRNT AND SCHEDULING j.

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

's . completion of the issue assessment and ranking (using, in some cases.

L the results of probabilistic risk assessment studies), the tasks asso-

.ciated with each issue resolution were scheduled based on their assigned-ranking and available resources. The' issues or issue resolutions were l .organised into Issue Groups'A and 5 based upon the origin of the issue y and its ranking. Completion schedules and. periodic status reports identify critical ~ project taska, target completion dates, progress and l problem areas which enable management to develop contingency.and/or i 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.

Issue-Croup B - Issues (of either a generic or plant specific nature) identified by the NRC or CPC which have resolutions l

and/or completion dates committed to by CPC, and which would result in either a) plant modifications,

!= b) procedure revisions, or c)' changes in facility staffing requirements.

l L -Issue resolutions and/or implementation dates in Issue Group A may be L modified or deleted only with prior approval of the NRC, in accordance

with existing NRC regulations. Changes to the issue resolution and/or J completion dates in' Issue Group B require notification to the NRC as L described in Section V. Issue Groups A and B, taken together, provide a basis for assessing the overall effects of changes to issue resolutions l and/or schedules,-and a departure point for discussion between the NRC f and the licensee regarding such changes, as discussed below.

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'IV. ISSUE RESOLUTION AND SCHEDULE' MODIFICATIONS [

! ' :An_important aspect of CPC's' planning effort is the recognition that the t 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 'I from events beyond CPC's control. The procedure used by CPC for. chang- , i ing or deleting issues, issue resolutions, or scheduled completion dates will be developed and included in a separate volume of the Big Rock .

. Point Planc Manuals. g 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. As set forth herein the NRC will treat all  ;

Integrated Plan issues consistently and recognise that, when necessary,- ,

, ranking. issue resolutions, and/or scheduled completion date changes are  !

based on a comparison of the issue being changed to all the Integrated '

Plan issues, and also account for resource constraints. p A. PERIODIC UPDATING '

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

the following:

• Summarise progress in completing or. implementing issue resolutions.

'_ Identify changes since last update report.

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

. associated with regulatory. requirements.

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 works unplanned outages: results of investigations into an

.1 The listing of issues in Issue Groupe 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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'S issue'(eg, PRA findings); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or CPC actions.

Ib 'Where it is necessary to add's new issue or to change the schedule for an issue .the following general guidance will be utilised to the extent appropriate:

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

L Schedule the new or_ changed issue resolution to avoid rescheduling other issues, if.it.can be reasonably achieved.

• 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 penal-ties from reacheduling Issue Group 5 activities significantly-l outweigh the consequences of.a change in an Issue Group A completion ll .date. <As with proposals to add Issue Group A activities, proposals.

to change previously existing Issue Group A activities also' requires

. 's ., , NRC approval.

CPC will inform the.NAC 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

.. regulations.-

l Issue resolutions in Issue Group B may be modified, deleted or

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i-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 written notification of changes or deletions of Issue Group B' issue resolutions or comple-tion dates associated with NRC initiated issues at least 30 days prior to Plan-scheduled completion date. Such notification will also~ include the reasons for the change and describe any compensa-tory actions which CPC, determines to be appropriate.

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. NRC requests will be made within 15 days of receipt of CPC written notification. In this l ~TSB0585-0017D-NL02

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event, discussions will be initiated 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 schedule is established lln these discussions, such issue resolution and/or schedule will super-

.s, sede the issue resolution and/or schedule set forth in Issue 4

Group B. The revised issue resolution and/or schedule will be in-corporated in a revised Issue Group B in the next update submitted a 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.

r-In the event of unplanned delays, delays which become manifest within 30 days of the Plat-scheduled completion date or in the event of circumstances beyond CPC's control, CPC shall provide timely notification to.the NRC Project Manager of the revised twsue resolu-tion and/or schedule date and incorporate it in a revised Issue Group B fn 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 A. CONSUMERS POWER COMPANY ORICINATED CHANCES

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 CHANCES (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 action, the NRC, to the extent consistent with its overa11'regula-tory responsibilities and, unless public health, safety, or interest require otherwise, will take into account the impact of such action ,

on CPC's ability to complete effectively the issues in Issue l

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'such impact. Although any formal regulatory action (ie, regulatory rule, order, or license condition) taken by the NRC will be effec-

' tive 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.s .Any resulting changes in issues in Issue Group A will be (1) reviewed by the NRC, taking in account the overall 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 tg 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 L 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 l The licensee and the NRC recognise that the Plan itself may require l ,' future modifications. Accordingly, all Plan revisions will be submitted for prior NRC' approval in accordance with existing NRC regulations. The

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revisions will be made effective upon amendment issuance by the NRC.

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