ML20155F756
| ML20155F756 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/27/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20155F746 | List: |
| References | |
| NUDOCS 8806170040 | |
| Download: ML20155F756 (22) | |
Text
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UNITED STATES i
NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 i.,
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ENCLOSURE 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.122 TO PROVISIONAL OPERATING LICENSE NO. OPR-16 GPU NUCLEAR CORPORATION AND JERSET CENTRAL POWER & LIGHT COMPANY OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219
1.0 INTRODUCTION
By letter dated January 27, 1987, and supplemented March 16, 1988.
GPU Nuclear Corporation (GPUN, the licensee) submitted an application to amend the Oyster Creek Nuclear Generating Station, Provisional Operating License No. DPR-16, to incorporate the requirement to adhere to the "Plan
)
for the Long Range Plannino Progran for the Oyster Creek Nuclear i
GeneratingStation"(OCNGS).
In the licensee's submittal of Farch 16, 1988, the licensee made several minor plan changes in response to the staff's recuest. The licensee also made a minor change to the proposed license condition.
The infomation submitted by letter dated March 16,
)
1988 provided clarification of the January 27, 1987 submittal.
The Program was developed by GPUN to enable GPUN to effectively manage implementation of significant changes to OCNGS 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 GPUN or other agencies (e.g, the Institute for Nuclear Power Operations).
The primary program objectives are to (1) optimize the allocation of GPUN and NRC resources to those projects necessary to assure safe, reliable, and economic plant operation and (2) achieve the appropriate balance and prioritization among all proposed projects based on their relative value and effect regardless of source.
The "Plan for the Long Range Planning Program for the Oyster Creek Nuclear Generating Station" (Attachment 1) is the implementation vehicle for the long Range Planning Program.
The Plan 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. The fomat and content of this Plan closely follows the previously approved Big Rock Point Plan.
8806170040 880527 PDR ADOCK 05000219 P
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-2 2.0 EVALUATION 2.1 Plan Description The OCNGS Long Range Planning Program is based on a list of over 50 major projects and their completion dates each of which is assigned a priority resulting from an established assessment methed.
In general, this list will exclude minor capital and specific Operations and Maintenance funding requests (under $50,000) unless the project could have a critical impact on major planned activities (e.g., inspections with potential for adverse contingencies) or is mandated by the NRC. The assessment method involves ranking each project based on its importance relative to public safety (e.g., safe shutdown, radiological release potential), personnel safety, plant availability / capacity factor and economic incentive.
The scheduling of major projects takes into account projections for budgets and site manpower and engineering support reouirements for up to five years, on an item-by-item basis covering all major plant projects.
The Plan submitted by the licensee organizes the projects into Categories A, B and C based upon their origin. Completion schedules and periodic status reports identify critical project tasks, target corrpletion dates, progress and problem areas which enable management to develop contingency and/or schedule recovery plans. The three categories are described below:
Category A - All projects involving regulatory issues which have resolution dates mandated by NRC rules, orders or license conditions.
Category B - Projects involving issues identified by the NRC and/or GPUN for which comitments have been made to the NRC by GPUN.
The issue resolutions would result in significant (a) plant modifications, (b) procedure revisions, oe (c) changes in facility staffing requirements.
Category C - Other ma,ior projects, identified by GPUN or other regulatory agencies.
The Plan recognizes that projects, project scopes, and scheduled completion dates will need to be modified or deleted at times to reflect changes in regulatory requirements to accomodate those activities that GPUN finds necessary to improve plant efficiency and reliability, to incorporate the results of investigation into issues, and to take into account delays resulting from events beyond the licensee control.
. 2.2 Plan Implementation The licensee's January 27, 1987 submittal (as supplemented March 16,1988) incorporates a license condition requiring that GPUN follow the Plan and permits the licensee to make changes to the Plan and its issue resolutions and schedule for certain categories of issues in accordance with the provisions of the Plan. The staff has reviewed the licensee's Plan and has detennined that:
1.
Changes to issue resolutions and/or schedules for completion of major issues imposed by rule, order or license cone. tion (Category A projects) will require prior NRC approval.
2.
Issue resolutions and/or schedules for completion of ma,ior issues by the NRC and/or GPUN for which connitments hwa been made to NRC by GPUN (Category B projects) are identified and provisions are made in the Plan to require GPUN to provide the NRC bith notification of changes to Category B projects.
3.
Schedules for completion of other major projects identified by GPllN or other regulatory agencies (Category C projects) are identified and provisions are made in the Plan to require GPUN to notify NRC on a semi-annual basis of changes, deletions or scheduling of Category C projects.
4 Provisions are made in the Plan for incorporating new or anticipatory major issues into Category A and B as these issues are identified by NRC and/or fonnalized by rule, order or license condition.
The licensee identified each planned major NRC-required modification and major non-NRC modification as an individual line item in its list of Category Projects. Semi-annual reports of licensee progress towards implementation of NRC-identified and licensee-identified modifications are proposed by the licensee.
The licensee's proposal to incorporate a condition into the Oyster Creek provisional operating license provides an appropriate mechanism to ensure that the NRC is informed as to whether required safety-related issues are being completed in a timely manner. The Plan also provides a suitable mechanism for changes to completion dates (due to unforeseen circumstances) for modifications not imposed by rule or order and for keeping the NRC informed of such changes for its consideration. Thus, the degree of flexibility needed to assure effective program implementation is provided while at the same time ensuring the the NRC's responsibilities are not compromised.
I
4 The Plan and the proposed license condition submitted by the licensee are functionally identical to those approved by the staff in Amendment No.
82 to the Big Rock Point Plant operating license, Amendment No. 75 to the Pilgrim Nuclear Power Station operating license and Amendment No. 91 to the Ouane Arnold Energy Center (DAEC) operating license. A copy of An.endment No. 91 was transmitted to all power reactor licensees by Generic t.etter 63-20 on May 9, 1983. This letter identified the approach addressed by Amendment No. 91 as one which is acceptable to the NRC.
Therefore, the staff has deter 1nined that (1) the Plan proposed by GPUN is equivalent to a previously approved plan, and (2) the license condition proposed by GPUN is equivalent to the previously approved license condition for Big Rock Point Plant on this subject.
2.3 Proposed Issues and Schedules to this enclosure provides GPUN's proposed list of rajor projects and schedules for completion of presently known GPUN-planned and NRC-required r.odifications.
For modifications imposed by rule or order, the utility proposes cenpletion by the required dates, or has received an approval from the NRC for an extension of the deadline (e.g., Installation, of Torus Temperature Instrunentation and Temperature indication recorded in the control roce extension of deadline fron, refueling outage 11R to refueling outage 12R).
GPUN has proposed completion of other GPUN and NRC initiated codifications not required by rule or order on a schedule consistent with its previous contnitments. As a sample, significant regulatory issues in this category include installation of cathodic protection system to arrest or mitigate identified corrosion of the drywell wall and replacement of nylon type relays with Century Tefrel Bobbin Type Relays.
Based on our review of these projects and the remaining existing projects not listed above, we find the dates proposed by the licensee for completion of these modifi-cations to be acceptable.
2.4 Suntra ry Based on the considerations addressed herein, we find that:
1.
The proposal by GPUN, that its Plan be implemented by a license condition requiring the licensee to follow the Plan, is acceptable.
2.
The licensee's proposal stating that changes to implementation dates imposed by rule, orders or license conditions will require prior NRC approval is acceptable.
I
. 3.
Based upon our review, the completion dates proposed by the licensee in the submittal are reasonable.
i l
4.
The license condition and the Plan submitted by GPUN are equivalent to that already approved in Amendment No. 82 to the Big Rock Point Plant.
5.
GPUN and NRC should be cognizant that there are likely to be higher priority and more urgent safety issues that are not included in the list because the pro.iects do not exceed the threshold cost of $50,000 or are r,ot mandated by the NRC. The licensee tracks these safety issues using the GPUN licensing action item system for the OCNGS.
3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change to a requirement with respect to the installation or use of a facility component 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 finding that this amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, the amendment meets the eli categorical exclusion set forth in 10 CFR 51.22(c)gibility criteria for (9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assess-ment need be prepared in connection with the issuance of this amendment, l
4.0 CONCLUSION
The staff has concluded, based on' the considerations discussed above, 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 Q e Comission's regulations, and the issuance of the amendment will not be inimical to the comon defense and security nor to the health and safety of the public.
Dated:
May 27,1988 Principal Contributor: Alexander W. Dromerick Attachments:
1.
Plan for the Long Range Planning Program 2.
List of Major Projects and Schedules
'\\
ATTACHMENT 1 PLAN FOR THE LONG RANGE PLANNING PROGRM FOR THE OYSTER CREEK NUCLEAR GENERATING STATION I.
INTRODUCTION GPU Nuclear Corporation (GPUN) has developed a comprehensive program which will enable GPUN to effectively manage implementation of significant changes to the Oyster Creek Nuclear Generating Station (0.C.)
which have been required, or proposed by, the NRC, as well as other measures to enhance plant safety and relisbility which have been identified by GPUN or other agencies (e.g., the Institute of Nuclet Power Operations).
The program is identified as the "GPUN Long Range Planning Program".
This program was developed to assess, coordinate and schedule major work tasks or projects at 0.C., including those mandated or proposed by the NRC, or identified by GPUN and others.
The program objectives are to (1) satisfy regulatory requirements; (2) provide sufficient lead times for modifications; (3) minimize changes for operators; (4) effectively manage financial and human resources; and (5) specify the framework for changes to developed proiects and associated schedules.
This will be accomplished within the overall objective of plant safety and availability.
This program reflects the recognition by GPUN and the NRC that fiscal and manpower resources are finite and that a limit on the onsite manpower is necessary.
Routine functional plant operations and maintenance require a substantial portion of available resources, further limiting resources which can be applied to the resolution of non-routine but important regulatory and non-regulatory issues that arise.
The program integrates a significant portion of presently planned non-routine work at 0.C. over a nominal five-year period to ensure that tasks associated with issue resolution are properly assessed and effectively scheduled and coordinated.
It provides a means for new requirements to be acconinodated taking into account schedule and resource constraints, as well as the importance of implementing a new requirement. The purpose of this document is to describe the plan used to implement the program.
It 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.
The term project as used herein refers to the projected allocation of significant fiscal and manpower resources at 0.C.
The tem issue resolution as used herein refers to th actions necessary to resolve concerns (safety related or othenvise) which have been identified by the NRC or GPUN.
II.
SUMARY OF PROGRM DEVELOPMENT The program is based on a list of projects and their projected completion schedules each of which is assigned a priority resulting from an established assessment method.
The assessment method involves ranking each project based on its importance relative to public safety (e.g., safe shutdown, radiological release potential), personnel safety, plant availability / capacity factor and economic incentive. i
The scheduling of projects takes into account projections for budgets W site manpower and engineering support requirements for up to five yeart, on an item-by-item basis covering significant plant projects.
The list represents that significant portion of the O.C. work list and comitment list which is regularly modified and updated to meet changing conditions, including new NRC regulatory requirements.
The final product of this program is the assessment of projects and the development of associated schedules as discussed below.
III. ASSESSMENT AND SCHEDULING A first step in the development of this program involves the identification and listing of significant open issues and their associated resolutions.
Following initial screening and evaluation of identified issues, those whose proposed resolution will require significant planning or resources are defined as proposed projects to be considered in development of the list of projects approved and proposed for approval by GPUN for 0.C. over the next 5 years.
An assessment of all proposed projects is required to detennine their appropriate value/ worth and relative priority.
Upon completion of the project prioritization and subsequent ranking, the tasks are scheduled based on assigned priority, available resources and schedular constraints.
The projects are organized into Categories A, B and C based upon their origin.
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.
The three categories are briefly described below:
Category A - All projects involving regulatory issues which have resolution. dates mandated by NRC rules, orders or license conditions.
Category B - Projects involving issues identified by the NRC and/or GPUN for which comitments have been made to the NRC by GPUN.
The issue resolutions would result in significant a) plant modifications, b) procedure revisions, or c) changes in facility staffing requirements.
Category C - Other major projects, identified by GPUN or other regulatory agencies.
Projects and/or implementation dates in Category A may be modified or deleted only with prior approval of the NRC.
Changes to project scope and/or completion dates in Categories B and C require notification to the NRC as described in Section V.
Categories A, B and C, taken together, provide a basis for assessing the overall effects of changes to projects and/or schedules, and a departure point for discussion between the NRC and the licensee regarding such changes, as discussed below. 1 r
_g_
IV.
ISSUE RESOLUTION AND SCHEDULE MODIFICATIONS Project schedules for each planning cycle include required milestones for engineering, procurement and, where appropriate, regulatory review and approval.
Inability to meet these milestones may require changes to previous plans and schedules.
Accordingly, an important aspect of GPUN's planning effort is the recognition that projects, project scopes, and scheduled completion dates may need to be modifled or deleted at times to reflect changes in regulatory requirements, to accommodate those activities that GPUN finds necessary to improve plant efficiency and reliability, to incorporate the results of investigations into f *~ nes, and to take into account delays resulting from events beyond GPU
, controll.
The method used by GPUN for changing or deleting projects or scheduled con.pletion dates is established and will be incorporated in the Corporate Procedures.
V.
GPUN AND NRC RESPONSIBILITIES The proper functioning of the Long Range Planning Program requires that GPUN apply consistent criteria to the assessment of projects, monitor the progress of work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when a project scope or sch.dule change is needed.
As set forth herein the NRC will treat projects consistently and recognize that, when necessary, ranking, project scope, and/or scheduled completion date changes are based on a comparison of the project scopes and/or completion dates being changed to all projects, and also account for resource constraints.
A.
PERI 00!C UPDATING GPUN will update Categories A, B and C semi-annually and submit the revised listing of projects and completion schedules to the NRC, beginning six months following NRC approval of this plan.
The revised project listing will include the following:
o Sumarize progress in completing or implementing projects.
o Identify changes since last update report.
l o Sumarize the reasons for project scope and/or se' 9dule changes associated with regulatory requirements.
- The listing of projects in Categories A, B and C will contain sufficient 8
detail to identify those projects with tasks and/or completion dates keyed to refueling outages.
In such cases, a change in outage period (i.e., initiation or duration) shall not be considered a schedule change. t
B.
CHANGES TO ISSUE RESOLUTIONS AND/0R SCHEDULES Changes to the project listing may arise from a variety of reasons, such as new projects identified; modifications to the scope of scheduled work; unplanned outages; results of investigations into an issue (e.g., PRA findings); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or GPUN actions.
Where it is necessary to add a new project or to change the schedule for a project, the following general guidance will be utilized to the extent appropriate:
o Assess the priority of the project relative to all existing projects.
o Schedule the new or changed project to avoid rescheduling other projects, if it can be reasonably achieved, o Select a schedule for the new or changed project which will help in maintaining an optimum integrated program of work.
Addition of activities to Category A requires GPUN to propose appropriate projects and/or completion dates and requires NRC approval of such proposals.
Changes to previously established Category A resolutions and/or resolution implementation dates will be proposed only after GPUN has determined that changing Category G and C items will not significantly assist in maintaining Category A without change; or that safety, resource or schedule penalities from rescheduling Category B and C activities significantly outweigh the consequences of a change in a Category A completion date.
As with i
proposals to add Category A activities, proposals to change 1
previously existing Category A activities also requires NRC approval.
GPUN will infom the NRC Project Manager when serious consideration is given to requesting a change in Category A.
When GPUN determines that a change in Category A is necessary, it will submit a written request for NRC approval.
Projects in Category B or C may be modified, deleted or rescheduled, or new projects may be added to Category C by GPUN without NRC approval; however, GPUN will inform the NRC Project Manager once a change, deletion, or addition to Category B is necessary.
GPUN will provide the NRC with written notification of changes or deletions of Category B projects or completion dates associated with NRC initiated issues at a minimum in each semi-annual update but in any event at least 30 days prior to the scheduled completion date.
Such notification will also include the reasons for the change and describe any compensatory actions which GPUN detemines to be appropriate. I
The change, addition or deletion in Category B will go into effect upon evaluation by GPUN, unless the NRC, in writing, requests further explanation or discussion.
NRC requests will be made within 15 days of receipt of GPUN written notification.
In this event, discussions will be initiated to promptly develop a project scope and/or schedule which is mutually acceptable to GPUN and the NRC Project f4anager 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 project scope and/or schedule is established in these discussions, such project scope and/or schedule will supersede the project scope and/or schedule set forth in Category B.
The revised project scope and/or schedule will be incorporated in a revised Category B in the next update submitted to the NRC.
If a revised project scope and/or schedule cannot be established in these discussions, GPUN changes to projects scope and/or schedule will be effective unless subsequently modified by NRC Order.
In the event of unplanned delays, delays which become manifest within 30 days of the scheduled completien date or in the event of circumstances beyond GPUN's control, GPUN shall provide timely notification to the NRC Project f4anager of the revised project an/or schedule date and incorporate it in a revised Category B in the next update submitted to the NRC.
GPUN will provide notification of changes, deletions, additions or rescheduling of Category C projects to NRC semi-annually.
This is for information purposes.
VI.
NRC REVIEW As pointed out in Section V.B above, changes to project scope and/or schedules are inevitable.
Action required by the NRC is discussed below:
A.
GPU NUCLEAR ORIGINATED CHANGES
- 1. Upon receipt from GPUN of a request for modification of Category A, the NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide en the request.
- 2. If the request for a modification of Category A is denied, NRC shall promptly infonn GPUN and provide the reasons for denial.
- 3. NRC consideration of GPUN changes to non-Category A projects and/or schedules is covered by Section V.B. ii
B.
NRC ORIGINATED CHANGES (CATEGORY A)
Is is recognized that fomal NRC regulatory actions (i.e., 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 overall regulatory responsibilities and, unless public health, safety, or interest require otherwise, will take into account the impact of such action on GPUN's ability to complete effectively the projects in Categories A, B, and C; and in consultation with GPUN, will try to minimize such impact.
Although any formal regulatory action
)
(i.e., regulatory rule, order, or license condition) taken by the l
NRC will be effective in accordance with its terms without inclusion i
in Category A, the NRC and GPUN recognize the desirability of incorporating such action into Category A, particularly in order to incorporate at the same time any other appropriate changes in the Long Range Planning Program.
Accordingly, once such fomal regulatory action is taken (or earlier, if practicable), the NRC will provide GPUN a reasonable opportunity to propose overall changes in the Long Range Planning Program which would most effectively accomodate such requirements.
Any resulting changes in projects in Category A will be (1) reviewed by the NRC, taking in account the overall objective of the Long(Range Planning Program to use available resources effectively, and 2) if acceptable, approved by the NRC, and will thereupon be reflected in a revised Category A listing submitted by GPUN.
GPUN will inform the NRC of any resulting changes in Categories B and C in accordance with Section V above.
C.
NEW NRC ISSUES (CATEGORY B)
The NRC may, from time to time, identify new regulatory issues which may result in (a) plant modifications, (b) procedure revision or J
development, or (c) changes in facility staffing requirements.
With respect to issues which the NRC requests (1) scheduling infomation j
or (2) responses by a certain date, these issues may be included in Category B in accordance with the project priority resulting from GPUN assessment.
Projects and/or schedule date comitments resulting from GPUN evaluation will form the basis for discussions between the NRC and GPUN.
As for the case of NRC-originated changes to Category A issues, the NRC will provide GPUN a reasonable opportunity to propose overall changes in the total integrated plan program which would most effectively accomodate such issues.
Any resulting changes in the integrated plan program will thereupon be reflected in a revised Category B or C list submitted by GPUN. -
~
D.
INSPECTIONS AND AUDITS The Plan and the Long Range Planning Program implementation processes and procedures do not fall within the scope of GPUN's Quality Assurance Program or the requirements of 10CFR50 Appendix B.
The existence of the Plan does not change the extent or nature of NRC inspection or audit activities which would be applied in the absence of the Plan.
Specifically, the management processes by which resource limits are established and allocated are not subject to detailed audit or inspection.
GPUN will provide information as discussed in Section V for review and/or approval by NRC of the basis for the Category A and B project schedules.
Implementation of those projects are subject to inspection and audit as required by GPUN QA Program and NRC Regulations.
VII HODIFICATION TO THE PLAN The licensee and the NRC recognize that the Plan itself may require future modifications.
Accordingly, all Plan revisions will be submitted for prior NRC approval.
The revisions will be made effective on a mutually agreed date upon or subsequent to amendment issuance by the NRC.
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