ML20137Y763

Summary of 860212 Meeting W/Util & State of Nj in Bethesda,Md Re long-range Planning & Integrated Living Schedule Program.List of Attendees & Viewgraphs Encl

ML20137Y763
Person / Time
Site:	Oyster Creek
Issue date:	03/05/1986
From:	Donohew J Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
GL-85-07, GL-85-7, NUDOCS 8603120375
Download: ML20137Y763 (24)

Text

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UNITED STATES

?, NUCLEAR REGULATORY COMMISSION e U s

f WASHINGTON, D. C. 20655 f

'% , , , , , # March 5,1986 Docket No. 50-219 i

LICENSEES: GPU Nuclear Corporation Jersey Central Power and Light Company FACILITY: Oyster Creek Nuclear Generating Station

SUBJECT:

FEBRUARY 12, 1986, MEETING WITH GPU NUCLEAR CORPORATION (GPUN) TO DISCUSS THE GPUN LONG RANGE PLANNING AND INTEGRATED LIVING SCHEDULE PROGRAM FOR OYSTER CREEK 1

l On Wednesday, February 12, 1986, a meeting was held at NRC, Rethesda, l Maryland with GPUN, the licensee, on the licensee's long range planning I and integrated living schedule program. The staff issued Generic Letter (GL) 85-07 Implementation of Integrated Schedules for Plant Modifications, dated May 2,1985, to all operating reactor licensees.

The GL stated the Comission's Statement of Policy and Planning Guidance for 1985 that "an integrated implementation schedule for new and existing i requirements reflecting relative priorities should be established for

} each power reactor licensee" and requested each licensee's views on the

( Integrated Living Schedule (ILS) concept and its intentions. The licensee responded by letter dated August 27, 1985, stating it had implemented a long range planning activity for Oyster Creek and planned to work with the staff to develop an ILS for Oyster Creek. This meeting is part of the licensee's work with the staff to develop an ILS.

Attachment 1 is the list of individuals that attended the meeting.

Attachment 2 is the material handed out by the licensee in the meeting for its presentation. Attachment 3 is the material handed out by the staff. This is discussed further in these meeting minutes. The following is a sumary of the significant items discussed and the actions, if any, taken or proposed.

L This meeting, which was requested by the licensee, is a continuatinn

? of the meeting held on November 11, 1985, to discuss the licensee's l long range planning to complete defertnents from the Cycle 11 Refueling (Cycle 11R) outage. The summary for this meeting was issued by the staff on January 23, 1986.

The licensee started its presentation with the handout which is in Attachment 2. The licensee discussed the objectives, the organization and the advantages of its long range planning program. The manaoer for overall long range planning reports to the Vice President and l Director for Technical Functions who reports to the Office of the President. The manager for Oyster Creek Lono Range Planning reports to the manager for overall long range planning.

B403120375 360305 PDR ADOCM 0$000219 P POR

MAR 05 B86 The licensee discussed the elements of its ILS or long range planning program: work task identification, task scoring and prioritization, constraints, planning and scheduling and interaction with NRC. The licensee plans to use its risk assessment studies done for Oyster Creek in scoring and prioritizing tasks to develop an overall score for each project. The different attributes looked at in scoring or prioritizing projects are listed in Attachment 2.

The staff statei that the licensee needed to clearly define the long range planning process and its administrative controls so that the staff understands how tasks are defined within projects, how pro.iects are scored, how consistency is maintained between pro.iects, how resource constraints such as manpower are accounted for, how the oro.iects go through engineering, design, maintenance and construction and site review for scheduling, and how the ILS schedule is changed. It is these details that the staff needs to approve for an ILS for a plant. The staff handed out Attachment 3, the license condition for Big Rock Point and the Plan for the Rig Rock Point Assessment. This was issued by the staff for Big Rock Point on February 17, 1986.

The staff reouested that another meeting be held after the licensee has defined the details of its planning process, the schedule for individual tasks and the ifcense condition. The licensee stated that it would develop a schedule for these three items by February 28, 1986.

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MM N Jack N. Donoh Project Manager i BWR Project Di ectorate #1 Division of RWR Licensing Attachments:

1. List of Attendees

2. Licensee's handout

3. Staff's handout cc: R. Bernero i

G. Lainas C. Grimes K. Eccleston O!STRIBUTION

. Docket File TRotella NRC PDR Local POR JZwolinski JDonohew CJamerson OELD EJordan BGrimes ACRS (10)

JThoma ,

ORL:PD816 Drk L:PD#1 CJamerson - Jd p :ich :t Zwnlinski 3 /4 /86 p g86 . 3///86

March 5, 1986  :

The licensee discussed the elements of its ILS or long range planning program: work task identification, task scoring and prioritiration, constraints, planning and scheduling and interaction with NRC. The licensee plans to use its risk assessment studies done for Oyster Creek in scoring and prioritizing tasks to develop an overall score ,

for each project. The different attributes looked at in scoring or prioritizing projects are listed in Attachment 2.

The staff stated that the licensee needed to clearly define the long range planning process and its administrative controls so that the staff understands how tasks are defined within projects, how projects are scored, how consistency is maintained between projects, how resource constraints such as manpower are accounted for, how the projects go throuah engineering, design, maintenance and construction and site review for scheduling, and how the ILS schedule is changed. It it these details that the staff needs to approve for an ILS for a plant. The staff handed out Attachment 3, the license condition for Big Rock Point and the Plan for the Big Rock Point Assessment. This was issued by the staff for Big Rock Point on February 12, 1986.

The staff requested that another meeting be held after the licensee has defined the details of its planning process, the schedule for individual tasks and the license condition. The licensee stated that it would develop a schedule for these three items by February ?8, 1986.

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1 Q s M.dack N..

j U ohew, lect Manager

( BWR Project Directorate #1 Division of BWR Licensing l

I Attachments:

1. List of Attendees

2. Licensee's handout

3. Staff's handout

, cc: R. Bernero G. Lainas C. Grimes K. Eccleston

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l cc' G. F. Trowbridge, Esquire Resident Inspector l Shaw, Pittman, Potts and Trowbridge e/o U.S. NRC 1800 M Street, N.W. Post Office Box 445 Washington, D.C. 20036 Forked River, New Jersey 08731 J.B. Liberman, Esquire Commissioner Bishop, Liberman, Cook, et al. New Jersey Department of Energy 1155 Avenue of the Americas 101 Commerce Street New York, New York 10036 Newark, New Jersey 07102 l . Eugene Fisher, Assistant Director Regional Administrator, Region I Division of Environmental Quality U.S. Nuclear Regulatory Commission Department of Environmental 631 Park Avenue Protection King of Prussia, Pennsylvania 19406 380 Scotch Road Trenton, New Jersey 08628 BWR Licensing Manager Mr. P. B. Fiedler l GPU Nuclear Vice President & Director l 100 Interpace Parkway Oyster Creek Nuclear Generating l Parsippany, New Jersey 07054 Station 1 Post Office Box 388 l Deputy Attorney General Forked River, New Jersey 08731 State of New Jersey Department of Law and Public Safety l 36 West State Street - CN 112 l Trenton, New Jersev 08625 1

Mayor i

Lacey Township l

818 West Lacey Road Forked River, New Jersey 08731 1

D. G. Holland Licensing Manager l Oyster Creek Nuclear Generating Station Post Office Box 388 Forked River, New Jersey 08731 l

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• ATTACHMENT 1 MEETING WITH GPU NUCLEAR CORPORATION (GPUN)

TO DISCUSS LONG RANGE PLANNING AND INTEGRATED LIVING SCHEDULE PROGRAM' FEBRUARY 12, 1986 >

NAME ORGANIZATION J. Donohew NRC/NRR J. Thoma NRC/NRR R. Green State of New Jersey

• J. Thorpe GPUN  !

P. Czaya GPUN J. Chardos GPUN

! t E. O'Donnell GPUN l C. Grimes NRC/NRR J. Zwolinski NRC/NRR ,

l T. Rotella NRC/NRR l

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• Department of Radiation Protection i

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ATTACHMENT 2 oc l

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GPUN

! LONG RANGE PLANNING i

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! INTEGRATED LIVING SCHEDULE 1

l PROGRAM l

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i GPUN LONG' RANGE PLANNING PROGRAM OBJECTIVES

! o PROVIDE CENTRALIZED COORDINATION OF PLANT AND SUPPORT DIVISION PLANNING INTERFACES AND .

l ACTIVITIES o PROVIDE BASIS FOR TOTAL PLANT LIFE CYCLE t PERFORMANCE AND RESOURCE REQUIREMENT PROJECTIONS l

l 0 MANAGE LONG RANGE STRATEGIC PROGRAMS AND STUDIES ,

l (E.G., LIFE EXTENSION) l  :

l l 0 IDENTIFY. PLAN AND ONTROL WORKSCOPE FOR FUTURE OPERATING /0UTAGE CYCLES (~ 5 YEARS AHEAD) o DEVELOP INTEGRATED LlVING SCHEDULE (ILS) PRC6 RAM  ;

CONCEPT  :

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l LM G RANGE PLANNING GROUP

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l ORGANIZATION 1

HANAGER OYSTER CREEK LONG RANGE PLANNING TECMICAL MAINTENANCE CYSTER CREEK NUCLEAR RADIOLOGICAL FUfiLTICNS CONSTRUCTION PLANT ASSURANCE CONTROLS AND DIVISION AND FAC. DIV. DIVISION DIVISION ENVIRON. DIV.

REP. REP. REP. REP. REP.

Simplified Long Range Planning 4LS Pmcess .

REGUUUORY ~

REQUIREMENTS CONSTRAINTS INTEGRATED

.REGUUUORY

• BdDGET g- LNING SCHEDULE

. MANPOWER

• SCHEDULAR SAFETY IMPROVEMENTS V j PRalECr DevEtOe OeERATwo LONG OUTAGE IMPLEMENT

+ IDENTIFICATIONI - -).

PRIORITIZATION 4

RANGE CYCLE PLAN DEFPMTION PLAN PLANS PUWT AIAILAEHLITY -

IMPROVEMENTS INCENTWES

ADVANTAGES OF ILS PROGRAM l

l 0 EFFECTIVE LONG RANGE PLANNING EFFORT IMPOSSIBLE WITHOUT FLEXIBILITY l ON REGULATORY REQUIREMENTS o ALLOWS GPUN TO ESTABLISH REALISTIC C0dMITMENT DATES CONSISTENT WITH APPROVED ILS PROCESS o PROVIDES FORMAL MECHANISM FOR GPUN TO COMMUNICATE TO NRC THE REALITIES OF CONSTRAINTS ON THE RESOURCE AND PROJECT MANAGEMENT PROCESS l 0 PROVIDES MECHANISM FOR INTEGRATING NRR AND NRC REGION RECUIREMENTS AND PRIORITIES  !

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o PROVIDES MEANS OF ACCOMMODATING AND MINIf1IZING IMPACT OF NEW OR CHANGING REQUIREMENIS IN AN ORDERLY MANNER l

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ILS PROGRAM ELEMENTS o WORK TASK IDENTIFICATION

, REGULATORY MODIFICATIONS PLANT IMPROVEMENT MODIFICATIONS o TASK SCORING AND PRIORITIZATION NUCLEAR SAFETY PERSONNEL SAFETY PLANT AVAILABILITY / CAPACITY FACTOR ECONOMIC INCENTIVE QUALITY OF OPERATIONS / MAINTENANCE EXTERNAL IMPACT o RESOURCE AND OTHER CONSTRAINTS BUDGET MANPOWER RESOURCES WORK SPACE AND AREA RESTRICTIONS ALARA OUTAGE DURATION SCHEDULE LEAD TIME  :

TASK SEQUENCING o PLANNING AND SCHEDULING LEVELIZE RESOURCES CONSISTENT WITH CONSTRAINTS o INTERACTION WITH NRC INITIAL PROGRAM PLAN AND PROCESS  ;

PERIODIC STATUS REPORTING AND UPDATING

0 Project Land Time and Roeowce Laoding ProfHe Meer 1 h2 Meer 3 Deer 4 weer s

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Illustrative Example of AM of Priority and Resource Constrakit to LRP/K.S Program .

War 1 Wer 2 War 3 War 4 War 5 i nosowce consereines i . .

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$VlYA x kkN11.hkk hkkkkhkkk asmswssuswasxsenw gy ILS Schedute A Projects --;; .9: _n " :1- y Projects V/////) N.S Schedule 8 Projects O i i a + ar a io .

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INTEGRATED LIVING SCHEDULE PLAN [

l ISSUES TO BE ADDRESSED l

l o CONTENT OF ILS AMENDMENT l LICENSE CONDITION REFERENCES ILS PLAN ONLY ILS PLAN SUBMITTED FOR STAFF REVIEW l DETAILED SCHEDULE INFORMATION PROVIDED IN ACCORDANCE WITH PLAN l -

0 CATEGORIZATION OF PROJECTS CATEGORY A - REGULATORY REQUIREMENTS WITH IMPLEMENTATION DATES MANDATED BY RULE. ORDER OR LICENSE CONDITION  !

CATEGORY B - OTHER REGULATORY REQUIREMENTS l

l CATEGORY C - NON-REGULATORY PROJECTS 1 i l o CHANGE NOTIFICATION AND APPROVAL PROCESS  !

l SEMIANNUAL UPDATE ON SCHEDULE INFORMATION i CATEGORY A - PRIOR NRC APPROVAL REQUIRED TO CHANGE I IMPLEMENTATION DATE COMMITMENT i 1

CATEGORY B - NOTIFICATICN AND OPPORTUNITY FOR NRC  !

l REVIEW PROVIDED ON CHANGES TO PLANNEL IMPLEMENTATION DATE l CATEGORY C - NO RECUIREMENTS l

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. o PROGRAM IMPLEMENTATION AND ENFORCEMENT l

PRIMARY INTERFACE BETWEEN GPUN LICENSING AND NRR  !

PROJECT MANAGER INFORMATION PROVIDED ROUTINELY TO NRC REGIONAL AND SITE l REPRESENTATIVES ,

ILS PLAN AND PROCEDURE NOT REQUIRED BY QA PROGRAM OR ,

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NO ADDITIONAL INSPECTION. AUDIT OR ENFORCEMENT RECulRE-MENTS IMPOSED AS A RESULT OF ILS PROGRAM i

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PROPOSED ILS PROGRAM MILESTONES l

DA THI-i i

INITIAL DISCUSSIONS 2/86 34D 0/66 WITH NRC SUBMITTAL OF DRAFT 2ND 0/SC 3RD 0/86 ILS PLAll l

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ATTACHMENT 3 l

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2. Accordingly, the license is amended by adding a to read as follows:

"(7). The ' Plan for the Big Rock Point Integrated As December 4, 1985, is approved, a.

The Plan shall be followed by the licensee from and after the effective date of this amendment.

b. Changes to dates for completion of issues identified in Issue Dates Group B of the Plan do not require a license am with applicable NRC procedures."

3. This license amendment is effective as of the date of its issua FOR THE NUCLEAR REGULATORY f

C0m !SSION

\ s s John . Zwo11nski, Director BWR P oject Directorate #1 Division of BWR Licensing

Attachment:

l' Changes to License No. DPR-6 l

Date of Issuance:

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Consumers Power Company ,

l Big Rock Point Plant Docket 50-155 / s' , .

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t Plan For the Big Rock Point Integrated Assessment l

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PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSM I. INTRODUCTION Consumers Power Company (CPC) has developed a comprehensive prog which will enable the Company to ef fectively manage been significant changes to our Big Rock Point Plant which have to enhance required, or proposed by, the NRC, as well as other d bymeasures the Company plant safety and reliability which have been identifieOperations). A or other agencies (eg, the Institute of Nuclear Power f description of the program, identified as the " Integrated Assessment t l d

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Open Issues and ScheduleThefor termIssue Resolution Issue Resolution to the NRC by our letter dated June 1, 1983 l oncerns as used herein refers to the actions necessary to reso ve c NRC or (safety related or otherwise) which have been ident CPC. ll This program was developed to assess, coordinate and schedule ainc necessary work at the Big Rock Point Plant, The program (2) provide proposed by the NRC, or identified by CPC and othe sufficient lead times for modifications; operators; (4) ef fectively manage financial and human resources; d and (5) specify the framework for changes to developed h erallissue resolut associated schedules. This will be accomplished within t e ov objective of plant safety and availability.

fiscal and This program reflects the recognition by CPC h and itethe manpower NRC that is manpower necessary.

resources are finite and that a limit on t e onsT l three-year planned work at the Big Rock Point Plant over a nominai period to ensure that the tasks associated with issue resolution are eIt provides ll as a mea coordinated.

dated taking into account schedule and resource constraints, as weThe the importance of implementing a new requirement. It am document is to describe the plan used f the NRCto and implemen d

and updating it, the interactions and responsibilities schedules.

II.

SUMMARY

OF PROGRAM DEVELOPMEhT l i s The program is based on a list of issues, their ity associated resulting reso u and completion dates, each of which is assigned a priorAssessments are pe nt from an established assessment method. i basedBig on itsRock Poi t tial, method involves ranking wach issue or issue reso L__

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personnel safety, and plant availability. The scheduling of issue resolutions takes into account projections for budgets and site manpower and engineering scyport requirements for three years, on an ites-by-item basis covering all significant plant modification activities. The list represents that significant portion of the Big Rock Point Plant work list and c~ommitment list which fs 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 resolutiens and the development of associsted schedules as discussed below.

III. ASSESSMENT AND SCHEDULING -

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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 tha 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 completion of the issue assessment and ranking (using, in some cases, 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 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 t resolution implementation dates mandated by NRC rules, orders or license conditions.

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 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 regulations. Changes to the issue resolution and/or completion dates in Issue Group B require notification to the NRC as d.escribed 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 schedulos, and a departure point for discussion between the NRC and the licenses 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 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 CPC's control. The procedure used by CPC for chang-ing or deleting issues, issue resolutions, or scheduled completion dates will be developed and included in a separate volume of the Big Rock Point Plant Manuals. g i

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 i Integrated Plan issues consistently and recognize that, when necessary, ranking, issue resolutions, and/or scheduled completion date changes are j

based on a comparison of the issue being changed to all the Integrated Plan issues, and also account for resource constraints.

j A. PERIODIC UPDATING f

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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; i

• Summarize progress in completing or implementing issue i 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 work; unplanned outages; results of investigations into an 1 The listing of issues.in Issue Groups A and B will contain sufficient -

detailsto 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 issue (eg, PRA findings); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or CPC actions.

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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 reistive to all existing Integrated Plan issue resolutions.

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

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

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• Select a schedule for the new or changed issue resolution which

i. will help in maintaining an optimum integrated program of work.

Addition of activities to Issue Group A requires CPC to propose-

) appfopriate issue resolutions and/or completion dates and requires NRC approval of such proposals. Changes to previously established l

Issue Group A resolutions and/or resolution implementation dates will be proposed only after CPC has determined that changing Issue Group B issues will not significantly assist in asintaining Issue Group A without change; or that safety, resource or schedule penal-

j ties from rescheduling Issue Group B activities significantly outweigh the consequences of a change in an Issue Group A completion data. As with proposals to add Issue Group A activities, proposals l8

' to change previously existing Issue Group A activities also requires jl NRC approval.

1 CPC will inform the NRC Project Manager when serious consideration

'l 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.

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

!* rescheduled, or new issues may be added to Issue Group 8 by CPC without NRC approval; however CPC will inform the NRC Project Manager once 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 completion dates associated with NRC initiated issues at least 30 days ,

4 prior to Plan-scheduled completion date. Such notification will i

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also include the reasons for the change and describe any compensa-tory actions which CPC determines to be appropriate.

i The change, addition or deletion in Issue Group B will go into

,effect upon evaluation by the TRC, unless the NRC, in writing, ,

l requests further explanation or discussion. NRC requests will be j

ande within 15 days of receipt of CPC written notification. In this

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l If a revised issue resolution and/or schedule these discussions, such issue resolution and/or schedule w ill super-is established sede Group B.. the issue resolution and/or schedule se corporated in a revised Issus Group B in the next update submitte d.

t to the NRC. If a revised issue resolution and/or schedu2e i i cannot  ;

established in these discussions, CPC changes to issue resc d fied ut ons ,

and/or schedule dates will be effective unless subsequently mo i by NRC Order. .

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of circumstances beyond CPC's control, d Issue CPC sha li tion and/or schedule date and incorporate it in a revise

. Group B in the next update submitted to the NRC.

NRC REVIEW

,j VI.

As pointed out in Section V.B above, changes to the issues a j schedules are inevitable.

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A. CONSUMERS POWER COMPANY ORIGINATED CHANCES- .

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, , '1. Upon receipt from CPC of a request for modification of Issue d

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j Group A, the NRC will act promptly (consistent w

<  ; on the request in accordance with applicable procedures.

If the request for a modification of Issue. Group Aforis denied, 2.

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NRC shall promptly inform CPC and provide the reasons denial.

NRC consideration of CPC changes to non-Issue Group A issues 3.

and/or schedules is covered by Section V.B.

B. NRC ORIGINATED CHANGES (ISSUE GROUP A)

It is recognised that formal NRC(1) regulatory impose a new actions regulatory (ie, NRC rules f orders, or license conditions) mayrequirement In taking any such with a fixed j previously, identified regulatory requirement.ith its overall regula-

, action, the NRC, to the extent consistent w l h, safety, or interest

l. . tory responsibilities and, unless public hea t l require otherwise, will take into account the impset of such ac on CPC's ability to complete effectively the issues in Issue ,

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J 'l 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 effec-tive in accordance with its terms without inclusion in Issue i

Group A, the NRC and CPC recognize the desirability of incorporating such action into Issue Group A, particularly in order to incorporate '

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at the same time any other appropriate changes in the total inte-grated assessment program. Accordingly, once such formal regulatory l

j action is taken (or earlier, if practicable), the NRC will provide j

CPC a reasonable opportunity to propose overall changes in the total integrated assessment program which would most effective ly accom-medare such requirements. Any resulting changes in issues in Issus 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

] 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.

I C. NEW NRC ISSUES (ISSUE GROUP B)

The NRC may, from time to time, identify new regulatory 1,ssues which j

may result in (a) plant. modifications, (b) procedure revision orWith development, or (c) changes in facility staffing requirements.

.' respect to issues which the NRC requests (1) scheduling information

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' 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 y integrated plan program which would most effectively accommodate j

il such issues. Any resulting changes in the integrated plan program will thereupon be reflected in a revised Issue Group B submitted by ll CPC.

s l! VII. MODIFICATION TO THE PLAN d The' licensee and the NRC recognize that the Plan itself may require future modifications. Accordingly,'all Plan revisions will be submitted li j The for prior NRC approval in accordance with existing NRC regulations. f i

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

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