ML20148Q263
| ML20148Q263 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 03/31/1988 |
| From: | CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | |
| Shared Package | |
| ML20148Q241 | List: |
| References | |
| PROC-880331, NUDOCS 8804120376 | |
| Download: ML20148Q263 (8) | |
Text
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d Haddam Neck Plant Integrated Implementation Schedule Procram Plan I. Introduction 8 CYAPC0 has developed the Integrated Safety Assessment Program (ISAP) for the Haddam Neck Plant for the integrated evaluation, prioritiza- :
tion, and scheduling of plant-specific modifications and engineering evaluations. ISAP is intended to achieve a resource-efficient and
- cost-effective process for enhancing nuclear power plant safety and .
operation. ISAP accomplishes this objective by fostering corporate ;
assesnent and decision-making with respect to plant improvements and studies, and by facilitating an Integrated Implementation Schedule (IIS).
The purpose of this Program Plan is to describe the process CYAPC0 -
will follow under ISAP to develop the IIS for the Haddam Neck Plant. ,
The IIS resulting from the process described in t% Program Plan will be CYAPC0's controlling schedule for implementing modifications and -
engineering evaluations of a wi.ll-defined scope for the Haddam Neck Plant. The IIS will assure that in scheduling implementation of 4 projects (ad studies, available resources are devoted to the extent i practicable in a prioritized and cost effective manner. As such, the IIS ar.d this Program Plan fulfill a condition of the Haddam Neck Plant operating license.
This Program Plan describes in general the ISAP methodology and the role of ISAP in the scheduling of projects and studies. The Program Plan also addresses CYAPCO's organization and process for developing the IIS, CYAPC0's responsibilities with respect to submitting the schedule and updates to the NRC, the NRC's responsibilities with respect to review of the ISAP process and the IIS. end mechanisms for ,
changing and updating the Program Plan itself. !
! In summary, through ISAP and tha IIS process described in the Program ,
- Plan, CYAPC0 intends to achieve two primary objectives
- first, to '
optimize the allocation of CYAPC0 and NRC resources among those activ-
- ities necessary cr desirable to assure safe, reliable, and economic operation of the Haddam Neck Plant; and, second, to assure that both '
CYAPCO-initiated activities and NRC-required or recommended activities
, are evaluated and scheduled according to a consistent and integrated j methodology.
II. Qverview of ISAP and IIS Develooment The Haddam Neck Plant ISAP began in May 1985 as a pilot program a ronducted by CYAFC0 in conjunction with the NRC. As currently imple-mented, the issues, projects, and studies to be evaluated under ISAP for the Haddam Neck Plant include generally:
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1 o Current and pending licensing actions and requirements; o CYAPCO initiatives and plant improvement projects; r o CYAPC0's on-going engineering evaluations or studies; ,
o Any major taskt resulting from mandates of agencies other than ,
the NRC.
All of the above comprise the "topics" for evaluation and scheduling under ISAP. ISAP specifically encompasses CYAPCO's process for evalu-ating each topic to determine the optimal resolution (if any) and for -
making a priority determination for each proposed plant-specific modification. All of those projects which are well-defined and deemed to be warranted are ultimately scheduled in the IIS.
The following subsectiongrovide an overview of ISAP and the process
- used to develop the IIS. Figure 1 shows a simplified flow diagram for the entire process.
A. Analytical Rankina Model (ARM)
For ISAP, CYAPC0 utilizes the ARM for arriving at a prioritized rank-ing of projects proposed to resolve individual ISAP topics. The ARM
- will be specifically utilized to prioritize only specific proposed plant modifications. Ongoing engineering evaluations addressing ISAP i
topics will not be prioritized using the ARM. CYAPCO has found it to be a more meaningful approach to prioritize only the proposed modifi-cations once they have been identified as a result of the engineering studies. Therefore, those ISAP topics that have not yet resulted in ,
specific plant modifm.tions (i.e., the unresolved topics) will be deferred for further evaluation in ISAP. However, the schedule for ongoing engineering evaluations will be included in the IIS. l The ARM includes individual models for scoring thesi topic resolutions with respect to four attributes which have been judged to represent CYAPCO's goals and objectives for the Haddam Neck Plant. The four
, attribute models are:
o Public Safety - Impacts on the risk to pubile safety are deter- I mined utilizing deterministic and PRA (where applicable) evalua-tions, in conjunction with subjective judgement.
, (1) Further details have been previously submitted to t! e NRC in the Haddam Neck Plant ISAP Final Report, dated December 12, 1986 (Reference 1). However, because ISAP is an evolving process, the methodology described in Reference 1 and la the models provided there-in will be continut.lly refined. CYAPC0 therefore does not intend to !
incorporate Reference 1 into this Program Plan.
1 1
o Personnel Safety - Impacts on occupational radiation exposure and industrial safety are determined utilizing a combination of quantitative and qualitative factors.
o Ronomic Performance - Impacts on plant availability, efficiency, output and the core power rating are determined utilizing plant-specific models, o Personnel Productivity -
Impacts on people, equipment, and environment as they relate to work quality and productivity are determined by subjective judgement supplemented by available qualitative data.
1 The ARM includes a project scoring methodology, attribute weighting factors, and a process for arriving at a final integrated scora combining all four attribute impacts, or "benefits" (either positive or negative). The models have been submitted to the NRC in Reference 1 but, of course, are subject to ongoing development and change.
Ultimately, the ARM is utilized to develop an initial ranking of all projects evaluated based on a benefit / cost ratio. The value is based on the post-implementation attribute impacts determined by combining the attribute scores and dividing by the project cost. This initial ranking will be utilized in the next step in development of the IIS.
Note also that the ARM will be applied on a regular basis to incorpo-rate new projects as they are identified and to maintain an up-to-date input for the Initial Pricritization Screening / Integrated Implementa-tion Schedule scheduling process.
B. Initial Prioritization Screenina (IPS)
The overall ISAP evaluation is designed to provide an objective basis for ranking candidate plant improvement projects. However, the process cannot be completely mechanistic. The second step in the overall evaluation process -- and therefore in the development of the IIS -- is the IPS. The IPS is a screening process for the ARM initial project rankings to assur1 that the prioritization is reasonable, accurate, current, and appropriately reflects other external factors.
The IPS considers the ARM initial ranking with other factors, includ-ing current installation man-rem, data on the payback of implementa-tion costs, and management overview of the benefit / cost determination.
During the IPS, CYAPC0 also considers the impact of external factors important to the project ranking. These external factors include NRC actions and requirements, actions of state / local government agencies, actions of other federal regulatory agencies, and actions of industry organizations. These third party influences may dictate a higher or lower priority than would be indicated by the ARM alone. For example, CYAPC0 is required to operate the Haddam Neck Plant within NRC regula-tory requirements. To the extent specific requirements are applicable and CYAPC0 is not otherwise exempted, CYAPC0 will rank and schedule projects consistent with binding NRC orders and regulations, l
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Another important element of ISAP is the qualitative "threshold" concept, such that issues shown in the integrated assessment to be of little or no benefit will be deferred or dropped. This can occur, for example, if the proposed project has insufficient intrinsic benefit or if it is obviated by other projects which will be implemented. CYAPC0 considers candidate projects to be dropped during the IPS. As a resul t, the final project rankings to be utilized in development of the IIS will include only those ISAP projects that have been specifi-cally identified for implementation.
C. Intearated Imt,lementation Schedule (IIS).
The need for an IIS derives from the fact that available resources (dollars and manpower), ALARA goals, and available outage time are much less than required to immediately implement the current backlog of plant modifications and engineering studies identified to resolve all the ISAP topics. In addition, in order to meet regional power needs and corporate objectives, outage time must be minimized. The IIS therefore is intended to optimize CYAPC0's use of resources to implement projects and studies, consistent with certain "real-world" constraints.
Essentially, in the IIS, activities are scheduled based on considera-tion of many factors and constraints, including:
o The IPS evaluation, which includes ARM rankings; o Resource availability, including budgets (capital and expense),
manpower availability, and equipment / material availability; o Planned outage duration, which is based on regional electric po r needs and CYAPC0 initiatives; and o Personnel radiation exposure (ALARA), based on current ALARA I budgets. I While there is no "cookbook" approach to determining what projects ,
should be done during a given outage, the above factors are considered !
in an interactive IIS decision-making process incorporating the input i and review of krowledgeable people within the company, )
Generally, the starting point for the IIS for each outage is a given outage duration based on the minimum time required for refueling. !
Projects are selected to fit this outage schedule. This represents a l change from past practice, whereby the length of an outage was select-ed based on the usually long list of projects planned to be completed.
Given the scheduled outage duration, CYAPC0 initially selects projects to be completed based on the final IPS. If a high priority project a) can be supported by the necessary resources, including manpower, available man-rem, equipment, and dollars, and b) does not otherwise impact critical path for the outage, the project is scheduled. On the other hand, if a project cannot be supported by resources, it must be deferred until sucn time es the necessary resources are available. If l
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the project can be supported but would impact critical path, CYAPC0 subjectively considers the issue based on the ARM assessments, exter.
nal considerations, and other subjective factors prior to making a decision. For example, based on the completed evaluations of attribute impacts and the overall score, CYAPC0 decides whether the project is of such importance that it should override the outage schedule. If a project is deemed to be of such importance, it is scheduled and the outage extended. If not, the project is deferred for consideration in the context of the next schedulad outage or implemented in more than one phase.
The IIS decision-making process incorporates management overview and the potential for multi-unit integration. This latter factor will ultimately allow Northeast Utilities to fully coordinate and optimize utilization of resources across all of its nuclear power plants.
Finally, the IIS is a "living" schedule. It is revised as new projects and studies are identified and up-to-date information becomes available to define the applicable scheduling considerations and constraints.
III. Schedulina/ Modifications Each current IIS will be developed and issued based upon the ISAP prioritization and scheduling process described above. The IIS is a schedule for all projects and engineering studies CYAPC0 plans to undertake or that are in progress. The IIS may also incorrorate activities requiring significant resource expenditures that have not been included within the scope of ISAP.
As discussed above, an im)ortant aspect of CYAPCO's IIS planning effort is the recognition t1at the schedule will need to be modified at times to reflect changes in or newly-identified regulatory require-ments, incorporate newly identified resolutions to previously deferred ISAP topics, to accommodate new activities identified by CYAPCO to improve plant efficiency and reliability, and take into account delays resulting from events beyond CYAPCO's control. The procedures for determining the schedule outlined above will be followed for changes to the schedule. In addition, however, it is important that changes to the schedule be documented and that NRC play a role in the over-sight of the scheduling process. Accordingly, CYAPC0's responsi-bilitics with respect to modifying the IIS, the NRC's oversight role, and the interaction between CYAPC0 and the NRC are discussed below.
A. CYAPCO Resoonsibilities Inherent in the concept of ISAP and the IIS is a responsibility on the part of CYAPCO that it maintain the integrity of ISAP and the IIS, monitor the progress of all work undertaken, manage its activities to maintain the schedule, and act prorptly to take necessary actions when a schedule change is needed. )
In recognition of one aspect of this responsibility, CYAPCO will l update the IIS at least semi-annually and submit the revised schedules
. to the NRC. The first such revision will be submitted no later than six months following NRC approval of this Program Plan. In addition, CYAPC0 will:
, o Perform such ISAP priority determinations as are necessary to support the revised IIS; o Schedule new or changed activities to avoH rescheduling other activities well underway, if it can be reaso. 51y achieved; o Summarize progress in implementing plant modificatiens or engineering evaluations addressing NRC requirements or orders which have specific implementation dates; and o Identify changes since the last report.
Activities in the IIS may be rescheduled by CYAPCO, consistent with applicable regulations and orders, without NRC approval. CYAPC0 may also add new activities to the IIS without NRC approval, liowever, ISAP is an interactive program between CYAPC0 and the NRC. In addi-tion to the scheduling updates as described above, CYAPC0 will keep the NRC Project Manager informed as to: significant changes in the schedule for activities addressing NRC-initiated regulatory issues; changes to the scope of existing ISAP topics (e.g., changes to a project intended to resolve a topic); or the addition of new topics within the program.
B. BBC Oversicht 1
NRC will provide oversight to the IIS scheduling process based on a review of the IIS and periodic updates. The NRC will also monitor CYAPCO's adherence to the schedule. However, neither the IIS nor this Program Plan are considered to be formal parts of the associated Haddam Neck Plant license condition. Therefore, a license amendment is not necessary for changes in the IIS or this Program Plan, i ISAP and the IIS do not in any way limit the NRC's licensing or enforcement authority with respect to CYAPC0's binding legal obliga-tions. Accordingly, where an implementation date for an activity is fixed by binding NRC regulation or order, CYAPC0 is obligated to meet l the date or seek an appropriate enemption to the regulation or modifi-e cation to the order to support a later date in the IIS, or seek to eliminate the requirement in wholu or in part. Also, to the extent an activity in the IIS is based on an NRC-initir.ted regulatory issue, CYAPC0 is committed to continue to fulfill commitments at necessary to
- ' maintain substantive compliance with regulations. It is noted that the ISAP evaluation results may assist in forming the appropriate bases for schedular or permanent exemptions to regulations or othar NRC-mandated regulatory requirements.
CYAPCO's ISAP documentation and the IIS and updates are not subject to quality assurance requirements of 10 CFR Part 50, Appendu B. NRC oversight of ISAP and the IIS process therefore does not extend to audits of the documentation developed in the scheduling process.
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t CYAPCO recognizes that formal NRC regulatory actions (i.e., Orders or ;
i new regulations) may impose a new regulatory requirement with a fixed ;
date or establish a firm d7te for a previously identified regulatory requirement. In taking any such action, the NRC, to the extent consistent with its overall regulatory responsibilities and public health and safety, will take into account the impact of any such action on CYAPC0's ability to complete effectively the activities
- scheduled in the IIS. Accordingly, once such formal regulatory action l is taken (or earlier, if possible), the NRC will provide CYAPC0 a [
reasonable opportunity to evaluate proposed activities and determine a
- revised IIS in accordance with the procedures established above. '
CYAPC0 will inform the NRC of any resulting changes in the IIS as part of the semi-annual IIS update (see Section III.A).
In addition, the NRC may identify a new regulatory issue that could be determined to require some plant-specific resolution for the Haddam Neck Plant (e.g., a hardware or procedure modification). For these issues, the NRC will not specify completion dates, unless such a date is established by a generic regulation or order. Rather, the NRC will request that CYAPCO avaluate the topic under ISAP and incorporate the resulting activity into the IIS. CYAPC0 will establish a completion i date consistent with its priority relative to the activities already in the IIS and consistent with the other factors considered by CYAPC0 ;
in the scheduling process. CYAPC0 will inform the NRC of the proposed '
schedule as part of the semi-annual IIS update (see Section III. A). ,
IV. Modifications to the Prooram Plan l CYAPC0 recognizes that the Program Plan itself may require future revision as ISAP is further developed and refined. Accordingly, if
, such a modification is deemed necessary by CYAPC0, a revised Program ;
l Plan will be submitted for NRC review and approval. The revised '
i Prograr. Plan will become effective upon notification to CYAPCO of NRC
, approval.
V. References i
- 1. J. F. Opeka letter to C. I. Grimes, "Integrated Safety Assessment i
. Program -
Final Report for the Haddam Neck Pl ant ," dated '
December 12, 1986.
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3 i SAP FLOWCHART .
-- I ANALYTICAL RANKING INITIAL PRIORITIZATION INTEGRATED IMPLEMENTATION MODEL SCREENING SCHEDULE (ARM) (I P S ) (llS)
ATTRIBUTES 4 EXTERNAL FACTORS 4- - PROJECT SCHED 4- . COST PAYBACK PERIO['
-> PUBLIC -> 4-- - ENG. RESOURCES 4- . INSTL MAN-REM 4-- - DOLLAR BUDGET
- 4. MGMNT& DISC. REVIEW 4 - OUTAGE SCHED us PERSONNEL 4-ALARA
$ + SAFETY 4 8 9 > um
--> IPS PROJECT SPECIFIC gI INITIAL I RANKING I llS
[ ,
RANKING ECONOMIC PERFORMANCE 4 4 PERSONNEL PRODUCTIVITY 4 4 l
PROJECT COST RGURai 1 b~ _ - . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ __. _ ___ _ _____ _. ___________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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