ML20215L437
| ML20215L437 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/21/1986 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| GL-85-07, GL-85-7, LIC-86-526, NUDOCS 8610290035 | |
| Download: ML20215L437 (4) | |
Text
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000 October 21. J86 LIC-86-626 Mr. Frank J. Miraglia, Director Division of PWR - Licensing - B Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter OPPD (R. L. Andrews) to NRC (H. L. Thompson) dated July 9, 1986 (LIC-85-295)
Dear Mr. Miraglia:
Implementation of Integrated Schedules for Plant Modifications Generic Letter 85-07 The Omaha Public Power District has revised its schedule for developing an Integrated Living Schedule (ILS). Attached is an update of the survey information previously supplied to you in Reference 3.
The items marked with a vertical line are those items which have been updated.
Our desire remains to participate in this project, based on our assessment of the ILS concept and its potential advantages.
Sincerely, 8610290035 861021 DR ADOCK 05000205 R. L. Andrews PDR Division Manager Nuclear Production RLA/me Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 Mr. D. E. Sells, NRC Project Manager gj Mr. P. H. Harrell, NRC Senior Resident Inspector i.9 m..
Mtu'f*"fuie
~N ATTAClittEf4T I
EfCLOSIPF 7 rep 0 tie FOPPAT - GEliERIC LETTER 85-07 N A'ji MM'F:
Fort Calhcon Station Unit No. I flTIL IT /:
Oruha Public Pow"r District I.
_I NT E!!T I O.*!S A.
Intend to unrk uith the staff to develop l an ILS
~
Yes B.
llave reservatinns that must be resolved before develnpinq ILS C.
Do not presently intend to negotiate an
[LS with the staff D.
Plan to irplement an informal ILS only
((.
I,TATUS A.
If ynn an'.wered I.A above:
1.
llave you settled on a method for prioritizing the work at your plant (s)?
Circle Ono:
Yes tio If yes, select best description:
Engineering judgement Ar.alytic Hiearchy process Pi9 bated analysis Cos t-h"ne fi t at:al ysis Othi:r (ple:;c describe)
If en, provide estimated date 2nd or for selecting a ri:ethodology:
3rd Quarter 1987 Date or if not presently available, provide estimated date for scheduling the selectinn of a methodology:
estimated as
?.
Vhat is your estimated date for making a submittal to the NRC-or If not prxently availatile, planned date for 3rd or 4th sct'edulinq a submittal ta the fdtC Quarter 1987
REVISED 10/86 i
2 f
8.
If you answered I.B above:
i 1.
Please evolain your reservations en separate sheet (s) or provide your schedule for supplying an explanation See separate sheet (s)
N/A 4
or 3
Separate submittal scheduled ror
~Teate) i s
7.
If available to meet with the staff to discuss your concerns, propose a tine frame for such a meeting and j
provide a contact that can make arrangements I
Con tac t/ Time ' Frame Phone Number C..lf you answered I.C 1.
Would you he willing to meet with the staff to discuss the 1
development of an ILS for your facilityf si?
Circle One:
Yes No g
If yee,, propose a time f rame for such a meeting and provide l
a contact that can rake arranuements.
I Contact 4
Tine Frame Phene t' umber if no, any construrtive comments you have would he appreciated.
j ADDITIONALITF/;g j
Please male any suagestions you nay have as to how a utility sponsored availability / reliability pro,iert nicht he credited for plant safety l
enhancerren t.
Provide additional constructive comments af Oppropriate.
{
In order for a Integrated Living schedula to be effective, a utility must I
develop and utilize a prioritization system which will ensure schedules to l
be determined for both NRC and utility projects.
This prioritization system i
should ensure that the necessary factors are weighed and schedules are set realistically and fairly.
In some cases, utility-sponsored projects would Warrant a higher priority than an NRC project.
i
~
REVISED 10/86 a * '
III.
ADDITIONAL ITEMS Commentjj, (Continued) t The following is an example to demonstrate the thought process we believe is beneficial in tenns of developing a prioritization system.
Consider two pro-jects, one utility-sponsored, the second NRC-suggested.
The NRC-sponsored project requires a major modification.
This modification would provide an additional degree of redundancy to a particular system.
This system performs no accident mitigation function, it is simply to be utilized in monitoring the consequences of particularly remote accident. Nonetheless, this modification does, under certain scenarios, provide an added degree of assurance that the accident events will be known. And f or those scenarios, that information is valuable for understanding the accident.
Its benefit to the health and safety of the public depends upon the failure of one system in combination with a par-ticular accident, none of which the system can do anything about, nor which knowledge of will aid the safety of the public.
The utility-sponsored project relates to a modification to increase the reliability of a particular component of the plant.
The modification involves no safety considerations. The entire purpose of the modification is to make the system run a bit better, more effi-cientlj.
Yet by increasing ef ficiency, do you not increase safety in other ways?
By ensuring that a relatively minor system operates better, you decrease the like-lihood of smaller accidents from occurring.
To consider another case, the prioritization process and NRC acceptance thereof should allow for utility sponsored projects which do not result in the modifica-tion of any system.
For example, additional training for operating personnel on the existing plant systems may be or far greater value than the installation of an additional modifica tion to monitor the results of remote accident scenarios.
There is not a finite measuren.ent of what impact such training would have on safety en-hancement, yet judgement must also be credited in the prioritization process.
To prioritize and schedule within the limits of financial and human resources for any given time frame, the most effective use of those resources should allow util-ity-NRC agreement that will recognize ar.d allow for the timely implementation of those projects.