ML20202J111
| ML20202J111 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/03/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20202J108 | List: |
| References | |
| NUDOCS 9712110045 | |
| Download: ML20202J111 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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wAmwovow. o.c. some SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULA RELATED TO AMENDMENT NO.137TO FACILITY OPERATING LICENSE N AND AMENDMENT NO. 129 TO FACILITY OPERATING LICENSE NO. NPF-15 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE. CALIFORNIA I!iLCITY OF ANAHEIM. CALIFORNIA SAN ONOFRE NUCtEAR GENERATING STATION UNITS 2 AND 3 DOCKET NOS. 50 361 AND 50-362 1.0 JNTRODUCTION By a> plication dated January 4, 199fe Southern California Edison Company (SCE or t1e licensee) requested changes to facility Operating License Nos. NPF-10 and NPF 15 for San Onofre Nuclear Generating Station. Unit Nos. 2 and 3.
respectively. The proposed changes would delete License Condition 2.C(26) for-SONGS Unit 2 and License Condition 2.C(27) for SONGS 3. These license conditions require that SCE implement and maintain a plan for scheduling all ca) ital modifications based on an NRC approved Integrated Implementation Sc1edule Program Plan.
4 2.0 DISCUSSION On May 15, 1989. License Amendment Nos. 72 and 60 established an Integrated Implementation Schedule (115) Program by License Conditions 2,C(26) and 2.C(27) for SONGS 2 and 3. respectively.
The goal of this program is the implementation of capital modifications in a stable, controlled manner.
Projects with the greatest potential of enhancing the safe operation of the units are given the highest priority. The license conditions require SCE to update its schedules of capital r..odifications on a semi-annual basis.
The 11S methodology utilizes the Westinghouse Analytical Ranking Process (WARP) to determine the relative licensee comitted modification. potential safety significance of each The methodology requires that after the projects are ranked. they be evaluated using normal scheduling methods to determine their implementation schedules.
The highest ranked projects are evaluated first and scheduled for the earliest outage in which implementathn P
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2-constraints of a normal refueling outage would not be exceeded. The schedules of each unit are then separated into the 'following three lists as described below:
Schedule A All items which have implementation dates required by NRC regulations. N orders or license conditions.
. Schedule B Regulatory items (of either generic or plant specific nature) identified by the NRC which have implementation dates committed to by the licensee and which would result in either. (a) plant modifications. (b) procedure revisions, or (c) changes in facility staffing requirements: or items perceived by the licensee as prospective NRC requirements; or major tasks resulting from mandates of agencies other than the NRC. Also included are evaluations for major initiated issues not required by regulation, license conditions or orders.
Schedule C Licensee initiated plant betterment projects.
The program reflects limited outage time, financial resources, and manpower resources, while at the same time implements those modifications deemed necessary for enhanced plant safety.
It prnvides for integration of all future identified work into one comprehensive schedule and has built in mechanisms for changes to the schedule when 'new modifications are identified or when key program milestones cannot be achieved due to considerations beyond the control of the licensee.
The IIS program is based on a priority determination ~ to assist in maximizing the benefit derived from required capital projects. Since it is not always possible or beneficial to try to implement a large number of capital projects in a single outage, the program provides a mechanism for focusing attention on those projects of highst priority.
Schedule A dates may be modified only wlth prior NRC approval in accordance with existing K'C procedures.
Changes in Schedule B dates require written notification to the NRC. Schedule C dates are provided for information to allow the NRC to gain perspective on the current backfit load and may be changed at the licensee s discretion.
The IIS program requires that the licensee monitor the progress of the work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when a schedule change is needed. The licensee is required to update Schedules A. B. and C semi-annually and submit the revised schedules to the NRC.
In addition to updating schedules, the licensee is required to:
o 3-Summarize progress in implementing NRC requirements concerning plant o
modifications.
identify changes since the last report.
o Summarize the reasons for schedule changes associated with Schedules A o
and B.
Indicate the expected 9ercentage allocation of resources on regulatory o
and betterment projects for the next refueling / modification outage.
The first edition of the 11$ was sent to the NRC on November 15. 1989. As required it provided the Schedule A. B. and C items for the Cycle 6 Refueling Outage for SO4GS 2 and Cycles 5 and 6 for SONGS 3.
Subsequent editions of the 115 (through the 12th Edition) have provided the required schedules through Cycles 9 for SONGS 2 and 3.
The licensee states that regulatory project allocations for refueling outages have been steadily decreasing and are currently under 40 percent of resources.
Regulatory projects which have been added to schedules since the initial 11S letter have not affected the priority rankings of projects. WARP has only been used once since inception of the 115 Plan.
Normal SCE scheduling methods have been used for these new projects. Their implementation schedules were established in separate correspondence, other than the IIS letter. The bulk of the projects found on recent IIS letters have been betterment projects which have had their worth determined by SCE and are under its control for scheduling purposes.
3.0 EVALUATION The staff's evaluation of the licensee's request focused on the regulatory need for continuing the 115 program for the SONGS units, and considered the final policy statement on integrated schedules.
The requirements of License Condition 2.C(26) for SONGS Unit 2 and License Condition 2.C(27) for SONGS 3 are redundant to other mechanisms which are in place to respond track, and implement regulatory projects. Mechanisms for responding to NRC Rules and Orders. Notices of Violation. Generic Letters.
Licensee Event Reports, etc., are adequate to ensure proper control over the scheduling and implementation of new regulatory required projects generated from these documents. These mechanisms meet the intent of implementing capital moufications at SONGS 2 and 3 in a stable and controlled manner. The proposed change deletes an administrative means of tracking and scheduling NRC required plant modifications and license commitments.
It does not affect the plant configuration nor NRC mandated schedules for implementation of modifications.
The 115 effort is a voluntary collaboration between a licensee and the NRC designed to permit more effective use of licensee resources to implement plant cnanges and NRC resources to review them. The volunteer nature of this program, and the ability of licensees to withdraw from the program. is j
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4 detailed in the final policy statement on integrated schedules, published in the Federal Reaister on September 23. 1992 (57 FR 43886).
Tnis policy statement describes the policy the Commission intends to use.to promote voluntary implementation of licensee integrated schedules for-regulatory requirements and other activities at nuclear power plants. The policy statement specifically states that licensees may withdraw from the program upon notifying the NRC.
For plants that have committed to the IIS
_ program in a license condition, specific NRC approval is required to delete this commitment.
Based on the above discussion and evaluation. the staff finds acce) table the licensee's proposal to delete License Condition 2.C(26) for SONGS !Jnit 2 and License Condition 2.C(27) for SONGS 3.
4.0 STATE CONSULTATION
In accordance with the regulations of the Commission. the California State official was notified of the proposed issuance of the amendment. The State official had no coments.
5.0 ENVIRONMENTAL CONSIDERATION
These amendments relate to changes in.recordkeeping, reporting, or administrative procedures or requirements.
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b) no environmental im)act statement or environmental assessment need be prepared in connection wit1 the issuance of these amendments.
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6.0 CONCLUSION
The Comission 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. (2) such
' activities will be conducted in compliance with t!ie regulations of the Comission, and (3) the issuance of the amendment will not be inimical 'o the common defense and security or to the health and safety Of the public.
Principal Contributor:
M. Fields Date:
December 3, 1997
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