ML20138H610
| ML20138H610 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/11/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Rubenstein L Office of Nuclear Reactor Regulation |
| References | |
| 85-837, NUDOCS 8512170260 | |
| Download: ML20138H610 (17) | |
Text
.
e VIRGINIA ELECTRIC AND PoWEM COMPANY Ibcuwoxn,V1HOINIA 202GI W.L.StaWART Vaca Pames > mar NecLeam ormaatm==
December 11, 1985 Mr. Harold R. Denton, Director Serial No.85-837
' Office of Nuclear Reactor Regulation E&C/RWC/acm Attn:
Mr. Lester S. Rubenstein, Director Docket Nos. 50-338 PWR Project Directorate #2 50-339 Division'of PWR Licensing-A License Nos. NPF-4 U.S. Nuclear Regulatory Commission NPF-7 Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS NO. 1 AND 2 REQUEST FOR LICENSE AMENDMENT - INTEGRATED IMPLEMENTATION SCHEDULE In my letter dated July 5,1985 (Serial No.85-362), Virginia Electric and Power Company - (the Company) indicated that we would be submitting an Integrated Implementation Schedule (IIS) license amendment in December 1985.
Pursuant to 10 CFR50.90, we hereby request a revision to the Operating Licenses, NPF-4 and NPF-7, for the North Anna Power Station, Units No. 1 and 2.
The proposed revision adds a paragraph to each unit's license (see Enclosures 1 and 2) that requires the implementstion of the Company's Integrated Implementation Schedule Plan (the Plan).
The Plan is attached as Enclosure 3.
It provides a summary description of the mechanisms for changing and updating the implementation schedules developed under the Company's Integrated Implementation Schedule Program, the responsibilities of the NRC and our staffs with respect to the Plan, and the mechanisms for modifying the requirements of the Plan.
The implementation schedules, _which are not a part of the Plan, will be submitted at a later date.
Development and modification of these schedules vill be accomplished in conjunction with the NRC Project Manager as describt.d in the Plan.
The proposed change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and by the Safety Evaluation and Control Staff. As indicated in the enclosed Safety Evaluation (Enclosure 4), it has been determined that this request does not pose any unreviewed safety question as defined in 10 CFR 50.59 nor does it pose a significant hazards consideration as defined in 10 CFR 50.92.
We have evaluated this request in accordance with the criteria in 10 CFR 170.12. A check in the amount of $150 is enclosed as an application fee.
In order to obtain the initial NRC response on our submittal in 1
preparation for discussion of our proposed implementation schedules, we o0 rwn - a/nc'. new swront f,o 8512170260 851211 ri An - J. anicar tier oni,3 PDR ADOCK 05000338 to taauano P
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PSE (CApot!LL) ass (sant!Nctal FOB (BEMAn0YAl
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Visointa ELuctnic Awn Powna Courawy to Mri H. Denton would. like to meet with the appropriate NRC staff in January 1986. We will be contacting the NRC Licensing Project Manager for North Anna to arrange a mutually acceptable time. If you have any questions or require additional information to support this effort, please contact us, f
Very truly yours, k
W. L. Stewart
Enclosures:
- 1.. Proposed License Amendment Change to NPF-4 2.
Proposed License Amendment Change to NPF-7 3.
Integrated' Imp 1.m ntativa Scliedule Plan 4.
Safety Evaluation 5.
Application Fee cc:
Dr. J. Nelson Grace Regional Administrator NRC Region II Mr. Morris W. Branch NRC Resident Inspector North Anna Power Station Mr. Charles Price Department of. Health 109 Governor Street Richmond, Virginia 23219 Mr. Leon B. Engle-NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A i
m.
COMMONWEALTH OF VIRGINIA )
)
CITY OF RICHMOND
)
The foregoing document was acknowledged before me, in and for.the City and Comunonwealth aforesaid, today by W.
L.
Stewart who is Vice President Nuclear Operations, of Virginia Electric and Power Company.
He i's duly authorized to execute and file the foregoing document in behalf of that Company, :and the statements in the document are true to the best of his knowledge and belief.
' Acknowledged before me this
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e es ENCLOSURE I PROPOSED LICENSE MIENDMENT CHANGE TO NPF-4
7._
F. ~ The Integrated Implementation. Schedule Plan for North Anna Power Station Units 1 and 2 (the Plan) submitted on December 11, 1985, is approved.
Ja)
'The Plan shall be followed by the licensee from and after the effective date of this amendment.
b)
The provisions of this paragraph shall be effective for a period of.three' years following the date of issuance by the NRC and may be renewed upon application by the licensee.
~
G.
This amended license is effective as of the date.of issuance and shall expire at midnight, February 18, 2011.
FOR THE NUCLEAR REGULATORY COMMISSION Originally signed by-R. C. DeYoung for Roger S. Boyd, Director Division of Project Management Office of Nuclear Reactor Regulation
' Attachments:
1.
Construction Related Items to be completed prior to Initial Criticality 2.
Appendices A and B Technical Specification page changes 3.
Figure 1
- 4.. Table 1 Date of. Issuance: APR 1 1978 i
4 4
a e
m 4
s ENCLOSURE 2 PROPOSED LICENSE AifENDMENT CHANGE TO NPF-7 i
1
. E.
Physical Protection VEPCO shall fully implement and maintain in effect all provisions of the following Commission approved documents, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).
These approved documents consists of information withheld from public disclosure pursuant to 10 CFR 2.790(d):
(1)
- " North ' Anna Power Station Security Plan", dated January 12, 1979.
-(2)
" North Anna Power Station Safeguards Contingency Plan", dated May 1, 1980, submitted as a revised Chapter 8 to the Physical Security Plan, and submitted pursuant to 10 CFR 73.40.
The Contingency Plan shall be fully implemented, in accordance with 10 CFR ' 73.40(b), within 30 days of this approved by the Commission.
'(3)
" North Anna Power Station - Guard Training and Qualification Plan", dated September 15, 1980.
This Plan shall' be fully implemented in accordance with 10 CFR 73.55(b)(4), within 60
~
days of this approval by the Commission.
All security personnel shall be qualified as required in the above plans within two years of this approval.
F.
If VEPCO plans to remove or to make significant changes in the normal-operation of equipment that controls the amount of radioactivity in effluents from the North Anna Power Station, the NRC shall be notified in writing regardless of whether the change affects the amount of radioactivity in the effluents.
G.
VEPC0 shall report any violations of the requirements contained in Section 2, Items C. (3) through C. (21),
E, F and G of this license within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegram, mailgram, or facsimile transmission to the Director of the Regional Office, or his
' designate, no later than the first working day following the violation, with a' written followup report within 14 days.
H.
The Integrated Implementation Schedule Plan for North Anna Power Station Units 1 and 2 (the Plan) submitted on December 11, 1985, is approved.
a)
The Plan shall be followed by the licensee from and after the effective date of this amendment.
b)
The provisions of this paragraph shall be effective for a period of three years following the date of issuance by the NRC and may be renewed upon application by the licensee.
c e
~
I.- This license:is effective as of the date of issuance and shall expire February 19,12011 ~.
FOR THE NUCLEAR REGULATORY COMMISSION Original signed by Harold R. Denton Harold R. Denton, Director Office of Nuclear Reactor Regulation
Attachment:
Appendices'A & B Date of Issuance: -AUG 21 1980
k-O ENCLOSURE 3 INTEGRATED IMPLEMENTATION SCHEDULE PLAN c
,e_
Virginia Electric and Power Company Integrated Implementation Schedule Plan for the North Anna Power Station, Units 1 and 2 I.
INTRODUCTION This document describes the Integrated Implementation Schedule Plan (the Plan) to be used to implement Virginia Electric and Power Company's (the Company) Integrated Implementation Schedule Program (the Program) for the North Anna Power Station Units 1 and 2 (the Station).
The Plan provides a summary description of the Program, the mechanism for changing and/or updating implementation schedules, the interactions of U.S.
Nuclear Regulatory Commission (NRC) and Company staffs under the Plan, and the mechanisms for changing the Plan.
The Program enables the Company to effectively manage implementation of modifications to the Station that have been required or proposed by the NRC, as well as other measures to enhance the safety and performance of the Station identified by the Company. The Program objectives are to:
- Ensure conformance to regulatory requirements;
- Provide sufficient lead times for modifications;
- Minimize changes for operators;
- Assure that training requirements are fulfilled;
- Manage financial and human resources effectively; and
- Specify the framework for. making changes to developed implementation schedules.
The Plan recognizes that fiscal and manpower resources are finite and that the interest of plant safety and performance are best served by careful planning for the use of these resources.
The Plan integrates the presently planned work at the Station over a nominal three year period to ensure that work items are effectively scheduled and coordinated.
It also provides a means for new work items to be accommodated, taking into account schedule and resource constraints. The requirements of the Plan are fulfilled by the existence and maintenance of implementation schedules in accordance with the Plan. The internal schedules and the Company's internal planning and scheduling processes described in the Program which are used to generate schedules are not under the requirements of the license provision endorsing the Plan.
II.
PROGRAM DESCRIPTION
SUMMARY
The Program provides for a compilation and assessment of the work items currently in progress or planned. The compilation and assessment takes into account projections for budgets, manpower, and engineering support requirements for three years.
It represents a comprehensive picture of Station work which is regularly updated to reflect changing conditions, including new NRC regulatory requirements and issues. A primary product of the Program is the development of implementation schedules as discussed below.
77-LH-20238-6
.n III. IMP.(EMENTATION SCHEDULES Implementation schedules are developed to reflect major work items currentiy in progress or planned. The development process includes the schedules, estimates of resource requirements, establishment of relative priorittes and the methodology of integration. The major work items are l
organiicd into two implementation schedules:
Schedule A,.' Items which have implementation dates mandated by NRC regulations, orders or license conditions.
Schedule B - Items of e'ither a generic or-plant specific nature identified by the NRC which have implementation dates committed to by the Company and which would result in either a) plant modifications, b) procedure revisions, orc) changes in facility staffing requirements; and items identified by other agencies or the Company, in anticipation of requiree nts or for enhancement'of Station reliability or efficiency.
Where appropriate, implementation schedules will. identify completion dates keyed to refueling outages.
IV.
IMPl.EMENTATION SCHEDULE CHANGES
~
An important aspect of the Plan is the recognition that Schedule A and Schedule B
may need to be modified at time's.
Modifications to implementation schedules may arise from a variety of reasons, such as new work items; modification in the' scope of scheduled work; problems in delivery, procurement, etc.; changes in NRC rules and regulations; or other' NRC or Ccmpany actions.' It is 'important that the procedure used by-the Company for changing the schedules be docukented. The NRC must play a role in the oversight of the schedules; accordingly, it is important that the NRC's role, and the interaction between the NRC and the Company be clearly defined, as discussed below.
The Company will monitor the progress of the work undertaken, nanage its activities to maintain the schedule and act promptly to take necessary actions when a schejule change is needed.
When it is necessary to add i 'new. work. item or to n.odify the implemen-tation schedule for an existing item, the following general guidance 'will be utilized to the extent appropriate:,
Avoid where practical, rescheduling of items with implementation dates mandated by NRC regulations, orders, and license conditions.
Consider the relative priority of work items.
Select a schedule for the ne+or changed item which will he.lp in maintaining an optimum integrated program of work.
Minimize rescheduling of items currently scheduled.
In cases where a completion date is keyed to a refueling outage, a change in the outage period shall not be considered a schedule change.
/
77-LH-20238-7
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7:.
A.
Changes to Schedule A 1.
Changes to Schedule A are categorized as follows:
- l. Changes to existing implementation schedules b.
Addition of new items c.
Addition of items previously included on Schedule B 2.
Changes Initiated by the Company The Company may request NRC approval of changes to Schedule A in accordance with applicable NRC regulations. Such requests will be considered in a timely fashion by the NRC.
If the request for a modification of Schedule A is denied, the NRC shall promptly inform the Company and provide the reasons for denial.
3.
NRC Action Resulting in Changes The NRC may initiate action which will change Schedule A by issuing or revising applicable regulations, orders, or license conditions.-
Before taking such action, the NRC, to the extent consistent with its overall regulatory responsibilities, will take into account the impact of such action on the Company's ability to-effectively complete the items on Schedule.A and B,
and in consultation with the Company, will try to minimize such impact.
The Company will have the opportunity to present alternatives which effectively accommodate the NRC's proposed actions.
1 B.
Changes to Schedule B
- 1. Changes to Schedule B are categorized as follows
-a.
Changes to existing implementation schedules b.
Addition of new items 2.
Changes Initiated by the Company The Company may make changes to Schedule B items as circumstances require. When propsing planned delays to implementation schedules i
established by a-Company comitment for work items identified by the NRC, the following procedure will apply:
I a.
The Company will' notify the NRC in writing at least 30 days or as early as practical in advance of the implementation date j
affected and include with the written notification, the reasons for the change and any compensatory actions the Company plans
'to institute.
b.
The revised schedule proposed by the Company will go into effect unless. within 15 days of receipt of the notification, the NRC requests, in writing, further explanation or discussion concerning the change.
i f
77-LH-20238-8
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3 c.
If the NRC makes such a request, discussion will be initiated 4
to promptly develop a schedule which is mutually acceptable to the Company and the NRC Project Manager while considering overall program impact. During the course of the discussions
~the Schedule B dates in question are suspended pending the outcome of the discussion.
,l d.
If a new schedule is established during these discussions, it will be incorporated into the subsequent semiannual submittal to the NRC.
g e.
If a new schedule cannot be established during' these discussions, the schedule changes originally proposed by the Company will go into effect unless subsequently modified by NRC order.
In the event 'of unplanned delays 'or circumstances beyond the Company's control, the Company-shall promptly notify the NRC Project Manager of 'the new date and incorporate it in a revised Schedule B in the subsequent semiannual submittal:to the NRC.
5 3.
Changes initiated by the.NRC The NRC may identify new regulatory issues by means other than regulations, orders, or license conditions which ma
)a) plantmodifications,b) procedure revisions, or c) y result in changes in
. facility staffing, for which the NRC may request the Company to provide implementation schedules.
Such implementation schedules will be developed in discussions between the Company and the NRC consistent with the objectives of-this-Plan.
t V.
PERIODIC REPORTING The Company will submit an updated implementation schedule report to 'the NRC' semiannually.
In the updated report the Company will':
s Summarize implementation schedule changes since the last report.
Identify new items added to the report.
-Sumarize the. reason for schedule changes associated with regulatory issues.
VI. MODIFICATIONS TO THE PLAN
.s.
L
}
The Company and the NRCjrecognize that this Plan may require future modifications. Accordingly,'the Company will draft proposed modifications and submit a license amendment application for approval of the proposed q
s changes. The changes will become effective upon amendment' issuance by the
'NRC.
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ENCLOSURE 4 SAFETY EVALUATION
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1 SAFETY EVALUATION PROPOSED INTEGRATED IMPLEMENTATION SCHEDULE LICENSE AMENDMENT NORTH ANNA POWER STATION UNITS 1 AND 2 The attached paragraph would modify the North Anna license to require that Virginia Electric and Power Co. (the Company) follow the Integrated Implementation Schedule Plan for North Anna Power Station, Units 1 and 2 (the Plan).
This license amendment would remain in effect for 3 years from the date of NRC approval at which time it could be renewed if deemed appropriate by us.
The plan provides a summary description of the mechanisms for changing and updating the implementation schedules developed under the Company's Integrated Implementation Schedule, the responsibilities of the NRC and our staffs with respect to' the Plan and the mechanisms for modifying the requirements of the Plan.
The implementation schedules are not a part of the Plan.
50.59 Safety Review The proposed amendment and the Plan are administrative in that they commit to and provide the ground rules for negotiating schedules for major projects or comitments of interest to both the Company and the NRC. The proposed amendment does not change in any way the design or operation of the station. Consequer.tly, the change does not constitute an "unreviewed safety question" as defined in 10 CFR 50.59 since it does not (1) increase the probability of occurrence or the consequence of an accident or. malfunction,. (2) create the possibility of a different type of accident other than discussed in the UFSAR; and (3) reduce the margin of safety as defined in the basis for any Technical Specifications.
50.92 Significant Hazards' Review The Commission has provided standards (10 CFR 50.92 (c)) for determining
~ hether a significant hazards consideration exists. A proposed amendment to an w
operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the probability of a new or different kind of accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
This
~ hange results in additional controls on project and comitment c
ma'nagement that are not presently included in the license.
In addition, this change to the license is consistent with the NRC guidance suggested in Generict Letter 83-20 dated May 9, 1983 and Generic Letter 85-07 dated May 2, 1985.
As. a result, the change is in the category of Examples 2 and 7 of those types of license amendments that are considered unlikely ~to involve significant hazards considerations as published in the Federal Register, Volume. 48, No. 67, April 6, 1983, page 14870.
Example 2 cites, "A
change ~ that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications:
for example a more stringent surveillance requirement.
'77-RWC-2019R-2
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Example 7 cites, "A change to make a license conform to changes in the regulations, where the license change results in very minor changes to facility operations.
Since the change would not increase the probability or consequences of an accident, create the probability of a new accident or significantly reduce a safety margin, it has been determined that a significant hazards considerations as defined in 10 CFR 50.92 does not exist.
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~77-RWC-2019R-3 Y
F 4RetNIA ELECTRIC AND POWER COMPANY 01 018850 11/26/85 0188084 nica voJc Is.,
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NE DATE INVOICE NO /O.1 OESCT,lPTION Gr.OSS AMOUNT DISCOUNT NET AMOUNT 11 11/19/85 111915000 150 00 150 00 APPLICATION FEE 150 00 150 00 ATTACHED CHECK ISSUED AS PAYMENT OF ITEMS LISTED ABOVE PLEASE DETACH STU8 AND CASH CHECK PROMPTLY.
A BANK &
UST COMPANY N. A.
VOID D NOT CASHED IN 90 DAYS ray EX AC TLY ONE HU N DR E D FI FT Y AN D ; N0/10 0 **** *** ****** ********* **** * ***** *** * *** ***
- I BK CHECK NO.
DATE vtNoon NO AMOUNT UNITED STATES NUCLEAR 01 018850 11/2b/85 018804
$150 00 7 REGULATORY COMMISSION IdASHINGTON DC 20555 b
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