ML20235N391

Application for Amend to License DPR-50,consisting of Change Request 170,adding Plan for Long Range Planning Program

ML20235N391
Person / Time
Site:	Three Mile Island
Issue date:	07/13/1987
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20235N358	List: ML20235N354 ML20235N391
References
NUDOCS 8707200048
Download: ML20235N391 (12)

Text

--_ -____ - _ _ .

METROPOLITAN EDIS0N COMPANY JERSEY CENTRAL POWER 8 LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT 1 Operating License No. DPR-50 Docket No. 50-289 License Amendment Request No. 170 This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1. As a part of this request, proposed replacement pages for Appendix A are also included.

GPU NUCLEAR CORPORATION i

BY:

Vice Presidtnt & Director, TMI-l Sworn and Subscribed to before me this /34 day of Onfo , 1987.

7~

(

H HM h. 4 KlinD

/ Notary Pitblic S!!AE0^l P. L10Wij, t;0Mity pm MIDDLETOY:N B0llo oAUpyg cogq;yy C.Y CC;;tussloli Expgggts 3gg g gpyg Esisber, Pennerivania Assochtlon of cetuta; J

8707200048 070713 PDR ADOCK 0500(X?G9 P PDR

m y 4

L I

UNITEDSTATESOFAMERICd' NUCLEAR REGULATORY COMMISSION

.IN THE MATTER OF

.u DOCKET NO.-50-289 LICENSE NO. DPR-50 1

GPU NUCLEAR CORPORATION This is to certify that ~a copy of License' Amendment Request No.170 to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, has,'on the date given below, been. filed with executives of Londonderry Township, Dauphin County,-: Pennsylvania; Dauphin County, Pennsylvania', and the Pennsylvania Department of Environmental Resources, Bureau of Radiation Protection, by deposit in the. United States mail, addressed as follows:

Mr. Jay H. Kopp, Chairman Mr. Frederick S. Rice, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County-R. D. #1, Geyers Church Road Dauphin County. Courthouse Middletown, PA 17057 Harrisburg, PA 17120 Mr. Thomas Gerusky, Director 2 PA. Dept. of Environmental Resources  ;

Bureau of Radiation Protection

'P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR CORPORATION 1 ~

BY:

I Vice President & Director, TMI-l l

DATE: July 13, 1987

_- - - - - _ - - _ - _ - - - - - - - - - - - - - i

I THREE. MILE ISLAND NUCLEAR STATION-UNIT 1 OPERATING LICENSE NO. DPR-50 DOCKET NO. 50-289 LICENSE AMENDMENT REQUEST NO 170 Applicant hereby. requests' the Commission to amend the above captioned license as below and, pursuant to 10CFR50.91, an analysis concerning the determination -

of no significant hazards considerations is also presented:

Proposed License Amendment 2.C.9 Long Range Planning Program The " Plan.for the Long Range Planning Program for the Three Mile Island Nuclear Station - Unit 1" (the Plan) submitted by GPUN letter 5211-87-2108 dated: , 1987 is approved.

a. The Plan.shall .be followed by the licensee from and after the' effective date of this amendment.  !

b. The Category A schedule shall not be changed without prior approval from the NRC. . Categories B and C schedules may be changed without prior approval by NRC.

Discussion Generic Letter 85-07, dated May 2,1985 requested nuclear. power plant licensees to document intentions regarding implementation of the Integrated Implementation Schedule concept. GPU Nuclear responded by letter dated August 27, 1985 indicating our intention to pursue the development of an Integrated Implementation Schedule for both Oyster Creek and Three Mile Island-Unit 1. The proposed license-amendment incorporating the Plan for the Long Range Planning Program (which follows) into the operating license by reference as stated above is hereby requested.

This amendment request is to incorporate the Plan for the Long Range Planning Program (LRPP) into the Three Mile Island Nuclear Station-Unit 1 Operating License (DPR-50). The LRPP by itself has no safety function but the projects

. listed on the Long Range Plan may affect the function of safety systems or components at TMI-1. The LRPP will establish an improved basis for planning, scheduling and implementing significant plant changes.

The primary objectives of the Plan for the LRPP are:

1) To optimize the allocation of GPUN and NRC resources to those projects necessary to assure safe, reliable and economic plant operation.

2) . To achieve the appropriate balance and prioritization between GPUN

' initiated projects and NRC required projects.

l .

l I

l l The Plan contains three categories of projects, as follows:

Category A: All projects involving regulatory issues which have resolutions and/or issue resolution dates mandated by NRC rules, orders or license conditions.

i Scheduled completion for Category A items will be modified only upon receipt of prior approval from the NRC in accordance with applicable NRC procedures.

Category B: Projects involving issues identified by the NRC and/or GPUN for which written commitments 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.

GPUN will inform the TMI-1 NRR Project Manager when a change is made to the schedule for a Category B project. GPUN will provide the NRC with written notification of a change including the basis for the change and any compensatory action initiated.

Category C: Other major projects, identified by GPUN or other regulatory agencies.

GPUN will advise the NRC of changes to Category C projects semi-annually.

The long range planning function is not currently described in any Licensing Basis Document. It was initiated by GPUN in 1984 for Oyster Creek and later in 1985 for TMI-l to establish controls for the efficient utilization of resources to implement identified projects which significantly impact available resources. The proposed amendment would incorporate this function as a license condition.

The LRPP by itself has no safety function. The projects which comprise the Long Range Plan may affect the function of plant systems important to safety; however, any changes in plant configuration or operation resulting from projects in the Long Range Plan are required to be evaluated separately in accordance with safety review and/or configuration control procedures. The long range planning function results in a prioritization and ranking of projects so that appropriate implementation schedules can be established.

The proposed license amendment does not in and of itself result in any change to Technical Specifications. Therefore, margins of safety stated in Technical Specification bases are not changed.

Significant Hazards Consideration We have determined, based upon the above discussion, that this license amendment request involves no significant hazards considerations in that operation of TMI-1 in accordance with the proposed amendment will not:

1. Involve a significant increase in the probability or consequences of any i accident previously evaluated; or f

l

2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3. Involve a significant reduction 11 margin of safety.

In summary, the basis for the above determination is as follows:

1 The establishment as a license condition of the Plan for the Long Range Planning Program by itself performs no safety function. The long range I planning function does not directly change plant configuration or operation.

l- Projects contained in the Plan may affect systems important to safety; however, any impact resultil;g from these projects is evaluated separately in accordance with applicable safety review and/or configuration control procedures. As no changes to Technical Specifications occur as a direct result of this proposed amendment there is no change in margins of safety.

Implementation It is requested that the amendment authorizing this change become effective upon issuance.

Amendment Fee (10 CFR 170.21)

Pursuant to tile provision of 10 CFR 170.21, attached is a check for $150.00.

i

)

l 1

1 l

l

m PLAN FOR THE LONG RANGE PLANNING PROGRAM FOR THREE MILE ISLAND NUCLEAR STATION-UNIT 1 1

I. Introduction GPU Nuclear Corporation (GPUN) has developed a comprehensive program which will enable GPUN to effectively manage implementation of significant changes to Three Mile Island Nuclear Station - Unit 1 (TMI-1) 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 of Nuclear 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 TMI-1, 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 projects and associated schedu?es. 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. The program integrates a significant portion of presently planned work at TMI-1 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 accommodated 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 TMI-1. The term issue resolution as used herein refers to the actions necessary.to resolve concerns (safety related or otherwise) which have been identified by the NRC or GPUN.

II. Summary of Program 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.

The scheduling of projects takes into account projections for budgets and site manpower and engineering support requirements for up to five '

years, on an item-by-item basis covering significant plant modification activities. The list represents that significant portion of the TMI-1 i work list and commitment 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 TMI-1 over the next 5 years. With GPUN on a yearly budget cycle, proposed projects may not yet be formally approved and therefore are subject to changes with regard to funding approval. An assessment of all proposed projects is required to determine their appropriate value/ worth and relative priority. Upon l 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 l 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 resolutions an/or issue resolution dates mandated by NRC rules, orders or license conditions.

Category B - Projects involving issues identified by the NRC and/or GPUN for which commitments 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 bel ow.

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 will 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 will need to be modified 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 issues, and to take into account delays resulting from events beyond GPUN's controll . The method used by GPUN for changing or deleting projects or scheduled completion is proceduralized.

Y. 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 schedule 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. PERIODIC UPDATING GPUN will update Categories A, B and C semi-annually and submit the revised listing of projects and scheduled cycle dates to the NRC, beginning six months following NRC approval of this plan.

The revised project listing will include the following:

o Summarize progress in completing or implementing projects.

o Identify changes since last update report, o Summarize the reasons for project scope and/or schedule changes associated with regPlatory requirements.

I The listing of projects in Categories A, B and C will contain sufficient 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.

_ _ _ - - - - - - - - - - - - - - - - -- i

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 l 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 j schedule for a project, the following general guidance will be i utilized to the extent appropriate:

o Assess the priority of the project relative to all existing Long Range Plan projects. 3 l

o Schedule the new or changed project to avoid rescheduling other l projects, if it can be reasonably achieved. l l

o Select a schedule for the new or changed project which will help j in maintaining an optimum integrated program of work. j l'

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 B and C items will not significantly assist in maintaining Category A without change; or that safety, resource or schedule penalties from rescheduling Category B and C activities significantly outweigh the consequences of a change in a Category A completion date. As with proposals to add Category A )

activities, proposals to change previously existing Category A '

activities also requires NRC approval.

GPUN will inform 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 j submit a written request for NRC approval. {

1 Projects in Category B or C may be modified, deleted or rescheduled, or new projects may be added to Category C by GPUN l 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 scheduled completion date. Such notification will also include the reasons for the change and describe any compensatory actions which GPUN determines to be appropriate.

_4

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 Manager 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 t 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 completion or in the event of circumstances beyond GPUN's control, GPUN shall provide timely notification to the NRC Project Manager of the revised project and/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 on the request.

2. If the request for a modification of Category A is denied, NRC shall promptly inform 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.

1

B. NRC ORIGINATED CHANGES (CATEGORY A)

It is recognized that formal 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 irterest 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 NRC will be effective in accordance with its terms without inclusion 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 total integrated assessment program. Accordingly, once such formal regulatory action is taken (or earlier, if practicable), the NRC will provide GPUN a g reasonable opportunity to propose overall changes in the integrated assessment program which would most effectively accommodate such requirements. Any resulting changes in projects in Category A will be (1) reviewed by the NRC, taking into account the overall objective of the Long Range Planning Program to use '

available resources effectively, and (2) approved by the NRC in accordance with established procedures, 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 development, or (c) changes in facility staffing requirements. With respect to issues which the NRC requests (1) scheduling information 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 commitments resulting from GPUN evaluation will form l

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 accommodate 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.

9

m q 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 The existence of the Plan does not change the extent or nature B. '

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. j Implementation of those projects are subject to inspection and '

audit as required by GPUN QA Program and NRC Regulations.

VII. Modification To The Plan The licensee and the NRC recognize that the Plan itself may require future modifications. Accordingly, Plan revisions will be submitted for prior NRC approval. The revisions will be made effective on a mutually agreed date subsequent to amendment issuance by the NRC.

l