ML20154A101
| ML20154A101 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/12/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20154A073 | List: |
| References | |
| NUDOCS 8603030293 | |
| Download: ML20154A101 (5) | |
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/ b UNITED STATES f .
NUCLEAR REGULATORY COMMISSION i
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_j WASHINGTON, D. C. 20666 e )
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 82 TO FACILITY OPERATING LICENSE NO. DPR-6 CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET N0. 50-155
1.0 INTRODUCTION
By letter dated June 7, 1985, as revised September 3, 1985 and supplemented December 4, 1985, Consumers Power Company (CPC, the licensee) submitted an application to amend the Big Rock Point (the facility) Operating License DPR-6, to incorporate the requirement to adhere to the " Plan for the Big Rock Point Integrated Assessment" (the Plan).
In a March 18, 1983 letter to the NRC, CPC comitted to conduct a comprehensive integrated assessment of all open issues (both regulatory and non-regulatory) for the Big Rock Point Plant, and to develop a "living schedule" for resolution of the issues included in this l integrated assessment. The objective of this program is to enable CPC to obtain better control and management of available resources and.
to perform required activities in a manner which would enhance plant l safety. By letter dated June 1, 1983, CPC submitted a description of l the integrated assessment and scheduling approach, and the resulting schedule for issue resolution. Four updates have subsequently been submitted on February 2, 1984, August 14, 1984 February 12, 1985, and August 28, 1985.
The Plan establishes the method by which the NRC and CPC will implement the Big Rock Point Plant Integrated Assessment. The Plan describes the responsibilities and requirements associated with integrating issues, initiated by the NRC or CPC, into the Integrated Assessment. The i format and content of this Plan closely follows that of previously approved l plans (e.g., Duane Arnold Energy Center Amendment No. 91 and Pilgrim Nuclear Power Station Amendment No. 75). The Big Rock Point Plant Integrated
! Assessment is different from these other plans in that the resolution of l NRC or CPC initiated issues, as well as the schedule, is included in the assessment process via evaluation by the Big Rock Point Technical Review Group.
Therefore, both the issue resolution and the completion schedule can be topics of discussion and negotiation between CPC and the NRC. Since changes to any NRC initiated issue requires prior written notification to the NRC, except for unplanned delays or circumstances which require prior notification only, the staff finds this difference, as well as the entire Plan, acceptable.
l A Notice of Consideration of Issuance of Amendment to License and Proposed l No Significant Hazards Consideration Determination and Opportunity for l Hearing related to the requested action was published in the Federal Register on August 14, 1985 (50 FR 32792). No public comments or requests for hearing were received.
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t 2.0 EVALUATION 2.1 Plan Description The Big Rock Point Plant Integrated Assessment program (Attachment 1) is based on an assessment and computer-generated completion schedule of over 100 issues. These issues, both regulatory and non-regulatory, require '
the licensee to perform activities to enhance plant safety. Some of these safety-related issues require a minimal amount of available resources while others require a significant amount. Consequently, the scheduling and implementation processes which are required for safety-related modifications, are critical elements in improving overall plant safety. This program enables the licensee to obtain improved control and management of available
. resources thereby resulting in improved safety-related modifications as well as prompt implementation of such modifications. The implementation of this Plan is expected to result in improved-plant safety while maintaining high plant availability.
In order to maintain a separation of " required" issues versus " desired" issues, for issues already in the integrated assessment, the issues were divided into two issue groups. Issue Group A is composed of issue resolutions and schedules established by existing rule, order, or license condition. Issue Group B is comprised of :
Issues (of either a generic or plant-specific nature) identified by the NRC, CPC, or other agencies, which have resolutions and/or completion dates committed to by CPC and which would result in either (a) plant modifications, (b) prccedure revisions, or (c) changes in facility staffing requirements.
Although this Plan is comprehensive with regard to issue implementation, it could not possibly include all of the issues which may arise during future plant operation. Therefore, the Plan is structured so that additional required plant modifications can be integrated into the overall program with an identification of the impact of such new requirements on i the overall schedule. The specific requirements for program changes and additions are described below.
2.2 Plan Implementation The licensee's June 7, 1985 submittal (as revised and supplemented) i incorporates a license condition requiring that CPC follow the Plan and permits the licensee to make changes to the Plan and its issue resolutions and schedules for certain categories of issues in accordance with the provisions of the Plan. The staff has reviewed the licensee's Plan and has determined that:
- 1. Changes to issue resolutions and/or schedules for completion of issues imposed by rule, order, or license condition (Issue Group A issues) will continue to be sought through the exemption, amendment, or Order-date extension process.
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( 2. Issue resolutions and/or schedules for completion of other issues '
- (Issue Group B issues) are identified and provisions are made in l the Plan to require CPC to provide the NRC with prior notification of changes to Issue Group B to enable further explanaticn or discussion of such changes.
l 3. Provisions are made in the Plan for incorporating new regulatcry l issues into Issue Groups A and 8 as these issues are identified by I the NRC and/or formalized by rule Order or license condition.
Each of the original Integrated Assessment issues has been reviewed and discussed by the NRC in NUREG-0828 " Final Integrated Plant Safety Assessment Report for the Big Pock Point Plant," dated May 1984.
This license change provides an appropriate mechanism to ensure that the NRC is infomed as to whether required safety-related issues are being completed in a timely manner. Semiannual updates of issues in both I issue Group A and B are required to be submitted to the NRC beginning '
l 6 months following NRC approval of this Plan. Furthermore, specific requirements as to the contents of the changes in the Plan are required ;
to be identified in the Plan. At the same time, the Plan provides a suitable mechanism for changes to issue resolutionc and/or coc:pletion dates '
(due to unforeseen circumstances) for issues not imposed by rule, order, or license condition, and for keeping the fiRC informed of such changes for its consideration. Supplemental information was provided by CPC in the December 4,1985 submittal clarifying the issue resolution and schedule changing process. No substantive changes, however, were proposed. This :
Plan process is acceptable to the staff since the Plan requires incorporation.
of the revision in the next semiannual update ar.d notification of all revisions to the NRC Project Manager. Thus, the degree of flexibility needed ,
to ensure effective program implementation is provided while at the same time '
ensuring that the NRC's responsibilities are not compromised.
By letter dated September 3, 1985, CPC requested minor changes to the Plan. !
CPC's evaluation of the changes concludes that the critical path methodology
- for issue / task scheduling is not always warranted and should not be a requirement of the Plan. CPC's original application included this methodology.
This change is insignificant in that it does not affect the content or schedule of any issue / task currently included in the Plan. Furthermore, additions to the Plan must still be implemented as described in Section 2.2 of this evaluation. Therefore, the staff finds these minor changes to be acceptable.
By letter dated December 4, 1985, CPC submitted supplemental information to be incorporated into the Plan for purposes of adding clarity and wiinimizing vagueness. The staff has reviewed the supplemental information provided and has determined the proposed changes to be insignificant. Therefore, the proposed revisions have been incorporated in the Plan, l
The Plan and the proposed license condition submitted by the licensee are functionally identical to those approved by the staff in Amendment No. 75 i
to Pilgrim Nuclear Power Station operating license, and Amendment No. 91 to the Duane Arnold Energy Center (DAEC) operating license. A copy of Amendment No. 91 was transmitted to all power reactor licensees by Generic Letter 83-20 on May 9, 1983. This letter identified the approach addressed by Amendment No. 91 as one which is acceptable to the NRC. Thus, the staff has determined that (li the Plan proposed by CPC is equivalent to a previously approved Plan, and (2) the license condition proposed by CPC is equivalent to the previously approved license condition for DAEC on this subject.
2.3 Proposed Issues and Schedules Attachment 2 provides CPC's proposed issues and schedules for completion of all presently known CPC-planned and NRC-required modifications over a 3 year period.
i For requirements imposed by rule or order, the utility proposes completion by the required dates, or has received an approval from the NRC for en -
extension of the deadline (e.g., Environmental Qualification of Electrical Equipment (EEQ) extension of deadline, March 27, 1985, providing for an EEQ completfen of Novmeber 30,1985).
CPC has proposed completion of other CPC and NRC initiated modifications not required by rule or order on a schedule consistent with its previous commitments as a sarple, significant regulatory issues in this category include Control Rcom Design Review, Seismic Design Considerations and Ercrgency Operating Frocedure Upgrade. Based on our review of these issues and the remaining existing issues not listed above, we find the dates proposed by the licensee for completion of these modifications to be acceptable.
2.4 Stmmary Sased on the considerations addressed herein, we find that:
- 1. The proposal by CPC, that its Plan be implemented by a license condition recuiring the licensee to follow the Plan, is acceptable.
- 2. The licensee's proposal, stating that changes to implementation dates imposed by existing rule or order will continue to be sought through the exemption or order-date extension process, is acceptable.
- 3. Schedules for new requirements should be established for the facility on a plant-specific basis.
4, Based upon our review, the completion dates proposed by the licensee in the submittal are reasonable.
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! 5. The license condition and the Plan submitted by CPC are equivalent i 2
to that already approved by Amendment No. 75 to the Pilgrim Nuclear i Power Station and Amendment No. 91 to the Duane Arnold Energy Center.
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3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change to a requirement with respect to the installation or use of facility components located within the restricted
- area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational
- radiation exposure. The Comission has previously issued a proposed .
- 1 finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly,,this amendment meets the eligibility criteria for categorical exclusion set ,
- forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental (
impact statement or environmental assessment need be prepared in connection
- with the issuance of this amendment.
4.0 CONCLUSION
i The staff has concluded, based on the considerations discussed above, i
that: (1) there is reasonable assurance that the health and safety of the ;
public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations ard the issuance of this amendment will not be inimical to the
- comon defense and security or to the health and safety of the public. l i t j 5.0 ACKNOWLEDGEMENT !
j This evaluation was prepared by Thomas S. Rotella.
] Dated: February 12, 1986 ,
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