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f MAR 3 01987 y
ELEASED TO THE PDR MEMORANDUM FOR: Robert M. Bernero, NRR Richard W. Starostecki, R-I Richard E. Cunningham, NMSS-Denwood F.'Ross, RES Clemens J. Heltemes, Jr., AE0D Joseph Scinto, OGC THRU: John E. Zerbe, Acting Deputy Executive Director Regional Operations and Generic Requirements FROM: Thomas H. Cox, Senior Program Manager Regional Operations and Generic Requirements Staff
SUBJECT:
ISSUE IDENTIFICATION AND
SUMMARY
FOR CRGR MEETING NO. 112 Enclosed for.your information and use is the R0GR staff sunnary associated with the proposed Policy Statement on Integrated Schedules. This matter is scheduled for CRGR review at Meeting No.112 on Tuesday, April 7,1987, in Room 6110 MNBB, 3-5 p.m.
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b Thomas H. Cox Senior. Program Manager ROGR Staff
Enclosure:
As stated Distribution:
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DATE :3/30/87 :3/fc/87 0FFICIAL RECORD COPY
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Issue Identification and Summary on CRGR Review Item 3, Meeting No. 112 April 7, 1987 IDENTIFICATION Proposed Commission Policy Statement on Integrated Schedules.
OBJECTIVE The CRGR is requested to review and recommend in favor of issuing the proposed Commission Policy Statement for public comment.
.The objectives of the proposed Policy Statement are to:
- 1. Reiterate the Commission's interest and support for a voluntary integrated scheduling process at each operating nuclear power plant.
- 2. Establish guidelines to utility management involved and to encourage utilities to adopt integrated schedules by providing NRC endorsement of the overall process.
- 3. Describe the basic approach for implementing integrated schedules.
- 4. Initiate a dialogue with industry to develop basic criteria and procedures for the evaluation of an integrated scheduling process.
- 5. Delineate the NRC's role in the integrated scheduling process.
BACKGROUND The proposed Policy Statement was submitted for CRGR review by memorandum from H. R. Denton to J. H. Sniezek dated March 11, 1987. Enclosed with the transmittal memorandum were the following Attachments:
- 1. Information Provided for CRGR Review, responding to the information re-quirements of Section IV.B of the CRGR Charter, Rev. 3. September 1986.
- 2. Proposed Commission paper, subject: Integrated Schedules Policy Statement, with the following enclosures:
(a) Generic Letter 83-20, Integrated Scheduling for Implementation of Plant Modifications, dated May 9, 1983.
(b) Generic Letter 85-07, same subject, dated May 2,1985. l (c) Proposed Federal Register Notice of Publication for Comment of Commission Policy Statement on Integrated Schedules for Implementation of Plant Modifications, dated March 1987.
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- 3. Letter, L.V. Parscale, Chairman, AIF Subcommittee on Integrated Schedules, to K.T. Eccleston, NRC, subject: Draft Integrated Schedules Policy Statement, dated November 5, 1986.
- 4. Safety Issue Management System (SIMS) input data sheets (3), dated February 12, 1987.
s, The current proposed Policy Statement is the latest action in a series of related activities with the same general purpose -- to encourage the utilization of integrated schedules (IS) by licensees. It was intended that the IS would represent realistic schedules for the accomplishment of safety improvements, both utility-initiated and NRC-imposed, at operating reactors.
The schedules would be prioritized; i.e., reflecting both the relative ;
importance of individual safety improvements and the capability and intent of :
thelicenseetocompleteallworknecessarytoeffecttheimprovementsgA \ l summary chronology of IS activities over the last four years follows. ) l On May 3,1983, the Commission issued its first approval of an integrated schedule for a licensee--Amendment No. 91 to the Duane Arnold Energy Center (DAEC) operating license. The NRC evaluation supporting issuance of that amendment is a comprehensive and detailed account of the development of the IS, the specifics of the plan, the mechanisms for modifying the IS when necessary, and the interactions between NRC and licensee.
On May 9, 1983, the NRR Division of Licensing issued Generic Letter 83-20 to all operating reactor licensees which enclosed a copy of the DAEC license amendment and supporting evaluation. The purpose was to reiterate the Commission's endorsement of the IS concept and to encourage utilities to use either the DAEC model apprcach or to propose their own approach.
The Commission's Policy and Planning Guidance (NUREG-0885) for both 1984 and 1985 directed (item IV.A.4, Planning Guidance) that an integrated implementa-tion schedule for new and existing requirements reflecting relative priorities should be established for each power reactor licensee. It was intended that once dates had been established in the schedules, the Commission would vigor-ously enforce license conditions associated with such schedules.
On July 13, 1984, a license amendment similar to the original DAEC amendment was issued for Boston Edison Company's Pilgrim Nuclear Power Station.
On May 2, 1985, the NRR Division of Licensing issued Generic Letter 85-07 which again addressed all operating reactor licensees on the topic of 15. '
Staff intentions were described in a separate enclosure and a survey form was enclosed soliciting utility views, intentions, and concerns regarding IS. At the time of this letter, six applications for IS had been received since the initial DAEC license amendment in May 1983.
On July 9,1985, the original DAEC IS was granted a two year extension following an application for renewal by Icwa Electric Light and Power Company.
On October 25, 1905, staff participated in an industry seminar held to obtain a better understanding of the industry perspective regarding IS. Industry i
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representatives expressed concern about a lack of Commission guidance regarding the preparation and implementation of IS. Licensees were apprehensive about volunteering to work on IS without clear criteria or standards by which their {
proposals would be judged. They feared loss of independence in making scheduling decisions.
On February 12, 1986, Consumer Power's Big Rock Point facility received a license amendment establishing an IS.
The Commission Policy and Program Guidance for 1986 again reiterated the earlier PPGs. Under a new format and structure, the IS became embedded in Goal 1.14. Subsequent ED0 Program Guidance issued November 3,1986 (pp.10-11, item
- 14) directed NRR to submit to the EDO by December 1986 a proposed Commission Policy Statement to encourage licensees to participate in this program.
DISCUSSION NRR's proposed Policy offers IS on a completely voluntary basis; no new requirements or staff positions are to be imposed on licensees. Therefore, the proposed Policy is not subject to the analytical requirements and required findings of 10 CFR 50.109. However, certain analyses and responses to questions are provided for CRGR consideration, in accordance with the CRGR Charter.
It is clear that the Commission has for several years encouraged the imple-mentation of IS, but the current proposed Policy Statement, directed by the ED0 in November 1986 EDO Program Guidance, is the first external initiative that will have received the imprimatur of the Commission.
The proposed Policy Statement is a new approach to promoting a long-held concept that so far has not been adopted by many utilities. The survey taken as part of Generic Letter 05-07 showed that more than half of the respondent licensees were not interested in submitting an IS program to the NRC for review and approval. However, only six licensees indicated that they did not already have an IS process or did not intend to have one. The October 1986 industry seminar indicated that the utilities are wary about committing to work with NRC in what they perceive as an open-ended process lacking criteria or standards.
The current proposed Policy Statement covers the following points:
- 1. The major elements of a (licensee's) formal integrated scheduling process are:
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- a. A systematic process for identifying and deferMg scheduled activities.
- b. A means for prioritizing individual actions.
- c. An integrated scheduling plan supported by procedures for prioritizing and scheduling.
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- d. NRC review of the prioritization and scheduling process and approval of the plan and schedule.
- e. Licensee maintenance of the schedule, including periodic reports to NRC.
- 2. Selection of the prioritization methodology should be. decided'by the licensee.
- 3. It will be incumbent upon the licensee to provide a comprehensive description of the integrated scheduling process to the NRC staff.
- 4. The NRC proposes.to establish three categories of plants, with respect to IS:
- a. Plants with an IS license amendment
- b. Plants with submitted IS plan, but no license amendment
- c. Plants without a submitted 15 plan
- 5. NRC may impose deadlines for certain licensee actions notwithstanding an IS plan approved by issuance of a license amendment. Future rules that impose implementation schedules will specify the manner by which schedule extensions or relief may be requested by licensees with an approved IS plan.
- 6. k plant with a submitted IS plan but no license amendment will have an
" informal" plan that will assist in negotiating schedules for individual requirements on an individual basis.
- 7. Plants without a submitted plan will propose and justify schedules on an individual requirement basis.
- 8. The NRC Project Manager will have the overall responsibility for evaluating and approving the IS license amendment.
- 9. Final resolution of any schedule conflicts will be by the Director, NRR
> and senior utility management using the IS as a basis for negotiations.
ISSUES CRGR may wish to raise questions related to the following issues:
General:
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- 1. The proposed Policy reiterates, as was done in 1983 and 1985, that IS are valuable tools to manage all plant modification work. However, as the
.1986 industry seminar and the 1985 survey revealed, most utilities appear l convinced that IS are valuable and they intend to have them. They simply are not convinced that there is a clear benefit to submitting their prioritization, planning and scheduling process to the NRC for review l
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l and/or approval. It may be worth discussing what specific elements of this proposed policy:
- a. Explicitly describe advantages that will move a utility toward the desired submittal to NRC, and
- b. address the known concerns of the industry about lack of criteria and standards for NRC approval of their submittals.
- 2. The prior guidance contained in Enclosure 1 of Generic Letter 85-07 addressed staff intentions in at least two areas of consideration for 15 in more detail than is in the current proposed Policy. The differences in treatment of NRC imposed plant modifications versus licensee-initiated modifications were covered, as was an example advantage of havirq a license amendment approval of the IS (unnecessary to issue Confirmatory Orders for required post-TMI work). In the interest of strengthening the current proposed Policy from the standpoint of encouraging utility participation, such material could be worth including in the proposed Policy.
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- 1. On page 4 of the proposed enmiss4cn p;per, the second plant category listed refers to an IS plan that is " submitted." Staff sponsors of the proposed Policy state that staff will review the submittal and eventually issue an approval, probably in letter form, for the situation where the licensee does not want a license amendment. Perhaps the Policy Statement, in the cate would be "(gory listing
- 2) Plants withon page 4, should a submitted, state reviewed that and the second approved category integrated scheduling plan but without a license amendment." Such language would both reassure licensees that they could earn an approval for their efforts, and would state clearly for NRC that a plan would need approval before the licensee could expect to use it as a tool in negotiating schedules for individual work items.
- 2. Regarding the practical differences between categories 1) and 2), the CRGR might receive additional clarification on how the scheduling of work te be done to conform to a new staff position would be accomplished; i.e., wt.at interaction would take place between NRC and licensee, and what document, if any, would acknowledge the agreed upon schedule for the particular work item, for the two different plant categories defined?
- 3. The AIF comment letter does not indicate much enthusias: x 15. How broad a cross-section of utility management does the staff feel this letter represents? To what extent were the major elements of the proposed Policy discussed with AIF informally?
- 4. The proposed Policy is explicit that NRC will review the prioritization l
and scheduling process but will approve the overall plan and initial schedule (fourth element of the formal 15 process, page 3 of the Comniission paper). It is not clear what the review of the prioritization and scheduling methods would lead to. The AIF letter (Attachment 1,
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suggestion 2) states that NRC may intend to approve an overall IS plan, but that the prioritization and scheduling process itself should not be subject to NRC approval.
If prioritization and scheduling processes are the key structures in an overall IS planning process, how can NRC approve an overall IS plan if NRC
.is not satisfied that the prioritization process will in fact assign appropriate relative importances to safety significant activities. That is, isn't approval of the prioritization and scheduling process necessary to approval of the overall plan? Approval of the process would not preclude licensee's selection of the method of prioritization, but would indicate agreement with the validity of licensee's proposed implementation of its selected prioritization method. The proposal that the NRC would review the prioritization and scheduling process with the only objective being to " understand" it, seems inconsistent with the importance of prioritization and scheduling to the outcomes of the IS process.
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, MAR 101987
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i MEMORANDUM FOR: Robert M. Bernero, NRR Richard W. Starostecki, R-I Richard E. Cunningham, NMSS Denwood F. Ross, RES Clemens J. Heltemes, Jr., AE0D Joseph Scinto, OGC FROM: John E. Zerbe, Acting Chairman Comittee to Review Generic Requirements
SUBJECT:
CRGR MEETING NO. 112 The Comittee to Review Generic Requirements (CRGR) will meet on Tuesday, April 7, 1987, 1-5 p.m. in Room 6110 MNBB.
1-2 p.m. G. Arlotto (RES) will present for CRGR review the enclosed proposed revision to Branch Technical Position MEB-1 (SRP Section 3.6.2) concerning requirements relating to postulated arbitrary intermediate pipe ruptures in class 1, 2 and 3 piping. (Category 2 item.)
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2-3 p.m. W. Russell (NRR) will present for CRGR review the enclosed proposed Generic Letter concerning short-term technical specification improvements. (Category 2 item.)
3-5 p.m. J. Funches (NRR) will present for CRGR review the enclosed proposed policy statement concerning integrated schedules.
(Category 2 item.)
If a CRGR member cannot attend the meeting, it is his responsibility to assure that an alternate, who is approved by the CRGR Chairman, attends the meeting.
Persons making presentations to the CRGR are responsible for (1) assuring that the information required for CRGR review is provided to the Committee (CRGR Charter - IV.B), (2) coordinating and presenting views of other offices, (3) as appropriate, assuring that other offices are represented during the presenta-tion, and (4) assuring that agenda modifications are coordinated with the CRGR contact (Walt Schwink, x28639) and others involved with the presentation.
Division Directors or higher management should attend meetings addressing agenda items under their purview.
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MAR 18 887 In accordance with the ED0's March 29, 1984 memorandum to the Commission con- i cerning " Forwarding of CRGR Documents to the Public Document Room (PDR)," the !
enclosures, which contain predecisional information, will not be released to .
the PDR until the NRC has considered (in a public forum) or decided the matter addressed by the information.
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, ':5,1 John E. Zerbe, Acting Chairman Committee to Review Generic Requirements
Enclosure:
As stated cc: SECY Commission (5) -
V. Stello, Jr.
Office Directors Regional Administrators W. Parler G. Arlotto W. Russell J. Funches Distribution:
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.DATE :3/18/87 :3/6/87 : : : : :
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